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2 March 1995 GST/HST Interpretation 11620-6- Assessment of Tax Payable Unedited CRA Tags ETA 165(1), 168                                                                         11620-6(AT) March 2, 1995  XXXXX This is in response to your memorandum of February 15, 1995 to Alyson Trattner of this unit. ... However, there are some positive aspects in raising the assessment: •   If there is a pre-proposal credit or rebate due to the debtor, the Department will be able to offset a pre-proposal debit balance to the extent of that refund or rebate; •   The Department would be entitled to a share of any disbursements to be made to unsecured creditors under the proposal once the assessment is raised; By establishing itself as a creditor the Department can apply to the courts to annul a proposal if the Department felt there was default, delay or injustice; and •   As a creditor, the Department would be entitled to obtain information from the trustee and ensure that the trustee is looking after its interests. ... & Enforcement Unit  XXXXX c.c.: D. Bennett A. Trattner C. Antonelli ...

As correctly stated in your letter, under the simplified net tax calculation, a charity •   will remit only 60% of the GST collectible or collected on most taxable supplies (given that the charity does not claim input tax credits on those purchases). Therefore, when a charity sells books, audio tapes and videos, it should collect 7% GST on the sales but remit only 60% of the tax collected; and •   will remit 100% of the GST collected, on various items but most importantly, on sales of real and capital property. ... Yours truly, Lorrie Grannary Charities, Non-profit Organizations & Educational Services Public Service Bodies and Governments Division GST/HST Rulings and Interpretations Directorate c.c.:      J.A. ...

Les renseignements suivants étaient donnés dans votre message: •   La Société A, un résident inscrit, a conclu un contrat avec une entreprise chinoise en vertu duquel la Société A s'engage à effectuer la formation de la main-d'oeuvre nécessaire aux fins de l'exploitation XXXXX[.] •   La Société A a retenu les services de la Société C, qui est également un résident inscrit, afin que cette dernière dispense la formation requise. •   Selon l'entente intervenue entre la Société A et la Société C, une partie de la formation des employés doit être effectuée XXXXX alors que l'autre partie doit être effectuée XXXXX[.] •   La Société C facture mensuellement la Société A pour les services rendus au cours du mois. ... Parce qu'aucune disposition de détaxation ou d'exonération ne s'applique, le service de formation fourni par la Société C à la Société A est assujetti à la TPS au taux de 7 % aux termes des dispositions de l'article 165(1) de la Loi. ...

Background Information •   XXXXX is engaged in energy performance contracts with its customers. ... This dollar amount is determined after surveying and documenting all base year conditions, and identifying measures that will reduce this base year usage, given that no other changes are made to the customer's facility. •   XXXXX analyses utility bills on an ongoing basis, and at the end of each year, a reconciliation is provided which compares actual energy savings to date versus the estimated energy savings to date. •   If the guaranteed energy savings are not achieved (i.e., actual energy savings are less than estimated energy savings), then XXXXX must refund, or credit the customer for the amount of the shortfall. •   If energy savings are overachieved in a subsequent year (i.e., actual energy savings are greater than estimated energy savings), then the customer must pay or credit to XXXXX the amount of the overage, up to, but not exceeding any previous shortfalls paid to them by XXXXX Position:  XXXXX fax of XXXXX, 19 XXXXX stated in part, "We do not think this should be classed as a taxable transaction as the tax portions have already been handled.... ... Page 2 of the interpretation of March 17, 1997, stated in part, "... it appears that when the guaranteed savings are not achieved, there has been an overcharge for the services provided. ...

At some point in 19 XXXXX Ruling Requested You are requesting a ruling in respect of the following: •   That XXXXX is a "municipal transit service" as defined in section 1 of Part VI of Schedule V to the Excise Tax Act (the "ETA"), and therefore exempt under section 24 of that Part. •   If it is determined not to be a "municipal transit service" under the above definition, you are requesting that XXXXX be designated by the Minister to be a "municipal transit service" pursuant to section 24 of Part VI of Schedule V to the ETA. ... Section 1 of Part VI of Schedule V defines "municipal transit service" to mean "... a public passenger transportation service (other than a charter service or a service that is part of a tour) that is supplied by a transit authority all or substantially all of whose supplies are of public passenger transportation services provided within a particular municipality and its environs". ... As " XXXXX is basically providing an interregional passenger transportation service, it would not qualify for designation under section 24. ...

Background •   XXXXX has coordinated XXXXX arrangements between manufacturers who supply independent dealers with appliances, and the independent dealers who purchase appliances from the manufacturers. XXXXX itself never purchases appliances from the manufacturers involved in these arrangements according to XXXXX[.] •   XXXXX purchases a quantity of $XXXXX "coupons" from XXXXX[.] ... A new arrangement has been negotiated with XXXXX, whereby currently, the $XXXXX "coupons" are purchased from XXXXX for $XXXXX per "coupon". •   According to XXXXX, XXXXX treats the supply of "coupons" sold to XXXXX as being "zero-rated". ...

Services supplied to an individual Indian are relieved of tax in accordance with B-039R when the following conditions are met: •   the service is performed totally on reserve for an Indian who is on reserve at the time the service is performed, •   where the service is performed totally on reserve for property, the property is situated on reserve at the time the service is performed, or •   where the service is performed off reserve, the service is for real property interests on reserve. ... Generally, a supply of a service (other than a telecommunication service) will be seen as having been performed at least in part at a location off-reserve, and therefore not eligible for tax relief under B-039R, if: •   the service requires a person to perform a task (i.e., the supplier acting through one or more of its employees), and the person performs or physically carries out the task off reserve; or •   the service requires the operations of the supplier's equipment (e.g. computer), and the equipment used in the task is located off a reserve at the time the service is performed. ...

Statement of Facts Our understanding of the facts is as follows: •   In your legislation XXXXX all funds from the sale of a prepaid funeral contract are required to be placed into a trust account. •   If a consumer wishes to cancel his or her contract, he or she is able to do so and is entitled to a return of his or her funds plus income earned. •   Under the heading XXXXX under the terms and conditions of the draft prepaid funeral contract provided XXXXX XXXXX Ruling Requested The issue on which you need clarification pertains to the timing of payment of the HST, and former GST, when a funeral home sells a prepaid funeral to a client in the province of XXXXX. 1. ... Based on the information provided, the only amount of GST/HST that is payable to the Seller, who must account for this tax in its net tax and remit any net tax owing, at the time the contract is entered into, is the GST/HST in respect to the XXXXX % administrative fee, as indicated in ruling #1 above. ... Yours truly, Carolle Mercier Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... For UHT purposes, the Canada Revenue Agency (CRA) interprets the term “residential condominium unit” to mean a bounded space in a building that is (or is intended to be) both of the following: * designated or described as a separate unit in the building on a registered condominium or strata lot plan or description, or a similar plan or description registered under the laws of a province, and includes any interest in land pertaining to ownership of the unit; and * a dwelling unit. ... Sincerely, Chris Lewis Manager Real Property – Specialty Tax Unit Financial Institutions and Real Property Division GST/HST Rulings Directorate ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... STATEMENT OF FACTS Based on your correspondence, and your conversation with my colleague [...] on [mm/dd/yyyy], we understand that: 1. ... Sincerely, Chris Lewis Manager Real Property – Specialty Tax Unit Financial Institutions and Real Property Division GST/HST Rulings Directorate ...