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. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. ... The elements that should be present are: •   the intermediary will help either the supplier or the recipient or both, in the supply of a financial service, •   the supplier and/or recipient count on one or more intermediaries for assistance in the course of a supply of a financial service, and •   the intermediary is directly involved in the process of the provision of a financial service and will therefore, expend the time and effort necessary with the intent to effect a supply of a service described in paragraphs (a) to (i) of the definition of financial service. ...

Supplies made prior to XXXXX •   If a rebate claim relating to a period prior to XXXXX, has not been paid, the claim will be reviewed to ensure that the claimant has paid the GST/HST to the supplier. If the GST/HST was paid to the supplier, then the claim may be approved for payment. •   If a rebate claim relating to a period prior to XXXXX, has been paid, the claim may be reviewed to ensure that the claimant has paid the GST/HST to their supplier. ... Supplies made after XXXXX •   If a rebate claim includes purchases made after XXXXX, and the claim has been paid to the claimant, the rebate claim will be re-assessed for those purchases made after XXXXX. •   If a rebate claim has not been paid to the claimant and the rebate claim includes purchases made after XXXXX, the tax paid on those purchases made after that date will not qualify for a rebate. ...

. / 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. ... [Manufacturer] charged [Client] an amount equal to the luxury tax on the purchase of [#] subject vehicles. 5. ... [Client] remitted the luxury tax on the sales of [#] subject vehicles made to their customers, resulting in the double incidence of the luxury tax. ...

. / 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. ... Please note: * a person that is an affected owner of two or more residential properties on December 31 of a calendar year has to file separate UHT returns for each residential property for the calendar year; and * if there are two or more affected owners of a residential property on December 31 of a calendar year, each of the affected owners has to file a separate UHT return for the residential property for the calendar year. ... Sincerely, Chris Lewis Manager Real Property – Specialty Tax Unit Financial Institutions and Real Property Division GST/HST Rulings Directorate ...

9 March 1994 GST/HST Interpretation 11660-1[4]- of the Applicability of Section 273 of the Excise Tax Act to the Acquisition and Construction of Condominium Units Unedited CRA Tags ETA 273                                                                         Telephone: (613) 954-8585 Fax: (613) 990-1233 XXXXX 11660-1, XXXXX                 11840-3, 11950-1, 11950-2/XXXXX (wh) Attention: XXXXX Thank you for your memorandum received at Policy and Legislation on July 14, 1993, requesting a GST interpretation of the applicability of section 273 of the Excise Tax Act to the acquisition and construction of condominium units. ... To accomplish this they entered into a Joint Venture Agreement in June 1992, which was amended in August 1992, to make the following changes: (a) to increase the number of participants to 33 individuals and a corporation; (b) to change the purpose of the joint venture from "... acquiring, subdividing, completing, renting, maintaining, managing and selling the Development" to "... acquiring and subdividing the development"; (c) to register the land in the names of the participants as tenants-in-common, with designated undivided interests; instead of in the name of a Nominee Corporation, as trustee; (d) to specify that, upon completion of the building contract, and upon payment of the outstanding amounts, the title to each of the strata-titled units would be transferred to the person identified in the agreement, but that the transfer would not be from the Nominee Corporation; and (e) to attach the building contract the participants entered into in August 1992, to the Joint Venture Agreement 2. ...

Subsection 10(1) of the Place of Supply (GST/HST) Regulations provides, in part, that when a particular supplier makes a supply of a computer-related service and there is to be one final recipient of the service who acquires it under an agreement either with the particular supplier or another supplier, the supply is considered to be made in a particular province if there is a single ordinary location in the province at which the final recipient avails itself of the service, and either: •   the particular supplier maintains information sufficient to determine that location, or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ... For purposes of the Place of Supply (GST/HST) Regulations, a "computer-related service" includes "... a service involving the electronic storage of information and computer-to-computer transfer of information". ...

8 September 1994 GST/HST Interpretation 11745-5(glr)[2]- Definition of Automobile Unedited CRA Tags ETA 340(3)                                                                         Telephone: (613) 954-8585 Fax: (613) 990-1233 XXXXX File: 11745-5(glr), ss. 340(3) Attention: XXXXX XXXXX September 8, 1994 Attached is a copy of a memorandum dated October 19, 1993 (File 11745-5 XXXXX), written by Mr. ... Allwright, GTP: XXXXX             G. Ryhorchuk J.C. Laporte ...

20 June 1995 GST/HST Interpretation 11645-6[1]- Do the Provisions of Customs Notice N579, Canadian Goods Abroad, Apply to Goods Exported for Addition                                                                         11645-6(RMcK) Candace Breakwell A/Director Duties Relief Programs Trade Administration Branch                                           June 20, 1995 This refers to a note from the office of XXXXX concerning whether the provisions of Customs Notice N579, Canadian Goods Abroad, apply to goods exported for addition. ... The Press Release indicated that goods exported for the purpose of being serviced or further processed outside Canada will, upon re-importation, be subject to GST only on the value added outside Canada — that is the value of any work performed on the goods while outside Canada (plus of course, any Customs duties applicable on re-importation). ...

1 October 1996 GST/HST Interpretation 12000-3[1]- Registration of Taxi Operators Unedited CRA Tags ETA 123(1) taxi business; ETA 240(1.1)                                                                         Telephone: (613) 954-8585 Fax: (613) 990-1233 XXXXX                                                                                 12000-3(sb) Subsections 123(1) and 240(1.1) Attention: XXXXX This is in reply to your fax to Dave Caron of my staff dated August 28, 1996 in which you inquired as to whether the leasing of a taxi licence (a taxi franchise or a right to operate a taxi) is considered to be operating a taxi business and, therefore, requiring the lessor to be registered for GST purposes pursuant to subsection 240(1.1) of the Excise Tax Act, whether or not the lessor exceeds the small supplier threshold. ... Jones Director General Applications Division GST Rulings and Interpretations GOBI #: 3276(GEN) c.c.: M. ...

The GST would be applicable to the value of the goods in accordance with the following formula: A + B where A is the value of the processing, including the value of any goods that were added to the exported goods, and B is the remaining duties payable in respect of the processed goods. ... To qualify under this provision, the following conditions must be met: •   the goods must have originated in Canada or have previously been released and accounted for under section 32 of the Customs Act; •   they are being imported for the first time after having been exported for the purpose of having work performed on them outside Canada; and •   the goods were not, prior to importation, supplied outside Canada by way of sale, outside Canada by way of lease, in Canada in circumstances to which Part V of Schedule VI applies, or in Canada to a recipient who claimed or was entitled to claim, a rebate for tax paid on those goods under subsection 252(1). This change will be effective for goods released on or after April 1, 1991.                                                                         ...