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26 May 1998 GST/HST Ruling HQR0001101- Subdivision and Sale of Land Unedited CRA Tags ETA 136.1(1); ETA 190(3); ETA 165(1); ETA Sch V, Part I, 7(a); ETA Sch V, Part I, 5.2(a)                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue XXXXX                                                                                 Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0001101 XXXXX XXXXX                 Code: 11950-3; 11950-4;                                                                         May 26, 1998 Dear XXXXX Thank you for your letter of July 7, 1997 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transactions described below by your client, XXXXX. ... You have made a previous inquiry with our XXXXX office concerning this ruling to XXXXX and you have been informed of the following: •   In order to be considered "residential units", the cabins/cottages at XXXXX must be affixed to land. ... The cabins/cottages at XXXXX qualify as "residential units" and the exemption under section 7 Part I Schedule V applies to the supply of the land. •   The fact that the licence lots are not serviced does not prevent the cabins/cottages from qualifying as "residential units". ...

5 June 1998 GST/HST Interpretation HQR0000305- Permits Provided to Contractors and Inspection Services Provided Under Agreement Unedited CRA Tags ETA Sch V, Part VI, 20(c)                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario  XXXXX                                                                                K1A 0L5                XXXXX Case: HQR0000305  XXXXX June 5, 1998 Subject: GST/HST APPLICATION RULING Permits Provided to Contractors and Inspection Services Provided Under Agreement Dear XXXXX Thank you for your letter which was addressed to XXXXX and forwarded to Revenue Canada for reply concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transaction(s) described below. ... The designation and responsibilities of an XXXXX are set out in subsections 27(1) and 40(1) and section 28 of the XXXXX which state: 27(1) On receipt of an application, an Administrator may designate a person who holds an appropriate certificate of competency and meets the requirements of the regulations as a safety codes officer with respect to all or part of this Act and may designate the powers that a safety codes officer may exercise. 28 A safety codes officer may exercise the powers and duties of a safety codes officer only in accordance with the designation under section 27 and the safety codes officer's terms of employment. 40(1) On receipt of an application, a safety codes officer or other person designated by an Administrator may issue a permit to a person who complies with the requirements of this Act or issue a permit with respect to a thing, process or activity if it complies with the requirements of this Act. •   The General Policy Guide issued by the XXXXX regarding the XXXXX further clarifies the role of an XXXXX by stating: Designation ensures that a certified XXXXX provides services only under the umbrella of an accredited organization or the XXXXX The designation of authority to administer provisions of the Act will cease if a XXXXX leaves the service of an accredited body or the XXXXX 5. ... The following facts are drawn from the Agreement: The Corporation agrees to pay the Agency for the performance of the work assigned to the Agency, according to the rates set forth in an attachment to the agreement. •   According to the attachment, the Agency charges the Corporation for compliance monitoring, examination of drawings, investigations, consulting, and the preparation of quality management programs as well as travel expenses related to these activities. •   Also included in the attachment are rates (identified as electrical permit fees) charged by the Agency to contractors who carry out electrical work on the Corporation's property. ...

Statement of Facts Our understanding of the facts is as follows: •   The XXXXX is a "for-profit" corporation that is incorporated under the XXXXX XXXXX and is not registered for GST/HST purposes. ... In addition XXXXX expects to receive a tax rebate ($XXXXX through XXXXX[.] •   The XXXXX main activity is the funding of persons to conduct research projects. ... In the event that XXXXX I realizes returns, it will repay the long term no interest loan to XXXXX[.] •   XXXXX owns farm equipment valued at approximately $XXXXX which it leases to the XXXXX[.] ...

26 February 2002 GST/HST Interpretation 31085- Website Hosting Supplied to Indians Unedited CRA Tags Indian Act 87; GST/HST Technical Information Bulletin B-039R, GST Administration Policy — Application of GST to Indians Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 31085February 26, 2002 Subject: GST/HST INTERPRETATION Website hosting supplied to Indians Dear XXXXX: Thank you for your letter of April 20, 2000, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to supplies of website hosting provided to Indians. ... Generally, a supply of a service (other than a telecommunication service) will be performed at least in part at a location off-reserve, and therefore not eligible for tax relief under TIB-B039R, if: •   the service requires a person performing a task (i.e., the supplier acting through one or more of its employees), and the person performing or physically carrying out the task is situated off of a reserve at the time the activity is done; or •   the service includes operations performed by the supplier's computer equipment, and any of the computer equipment used in the task is located off a reserve at the time the activity is performed. ... Yours truly, Dwight Kostjuk Rulings Officer Aboriginal Affairs Unit Public Service Bodies & Governments Division Excise and GST/HST Rulings Directorate Encl.: TIB B-039R c.c.: Chron. ...

. / 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. ... You are a sole proprietor operating a vacation rental property titled […]. 2. ... According to the conversations between you and […][the Company], […], [the Company] notified that as of [mm/dd/yyyy], it will start to collect and remit the GST/HST on bookings made on its platform, on behalf of hosts that did not provide their GST/HST registration number. ...

20 March 1997 GST/HST Interpretation HQR0000548- The Eligibility of School Authorities to Claim Public Service Body Rebates Unedited CRA Tags ETA 259(4.1)                                                                         File: 11910-1(GN) Doc: HQR0000548 Rebate Section Small & Medium Enterprises Audit Directorate March 20, 1997 XXXXX This is in reply to your electronic message (e-mail) dated February 4, 1997, regarding the education sector. ...

23 April 1997 GST/HST Interpretation HQR0000571- Snow Removal and GST Unedited CRA Tags ETA 221; ETA 223; ETA 224; ETA 259 XXXXX Case: HQR0000571 XXXXX                 R 11890-01, 11895-04, 11665-04                                                                         April 23, 1997 Dear XXXXX Thank you for your letter of February 14, 1997 concerning the application of the Goods and Services Tax (GST) to the transactions described below. ... Generally persons are required to register for the GST if: •   they are providing taxable goods or services in Canada; and •   their total worldwide taxable revenues, including the taxable revenues of all associates, in the past four consecutive calendar quarters are more than $30,000 (this includes revenues from zero-rated goods and services and excludes revenues from supplies of capital property). ... Subsection 223(2) of the ETA and the " Input Tax Credit Information Regulations" made pursuant to that subsection require a supplier to provide the supplier's GST registration number to a recipient of a taxable supply if the recipient requests the number and requires it for the purposes of claiming an input tax credit or rebate of GST. ...

. •   Your client has an Internet business, which specializes in custom programming software for the home consumer. The business provides its services across Canada and the U.S. •   Your client also creates and manages web sites for companies that advertise on the Internet. •   Any work performed by your client, as part of the business, is performed entirely in the province of XXXXX. ...

Subsection 123(1) of the Excise Tax Act (the "Act") defines a "telecommunications facility" to be "... any facility, apparatus or other thing (including any wire, cable, radio, optical or other electromagnetic system, or any similar technical system, or any part thereof) that is used or is capable of being used for telecommunications". ... Pursuant to this section, a supply of a telecommunication service that consists of making telecommunications facilities available is made in a particular province if: •   all of the facilities that are made available are ordinarily located in that province; or •   where all of the facilities are not ordinarily located in that province, the invoice for the supply of the telecommunication service is sent to an address in that province. ...

17 July 1997 GST/HST Interpretation HQR0000018- Application of GST/HST to Frames and Lenses Which are Specially Designed Parts for Prescription Eyeglasses Unedited CRA Tags ETA Sch VI, Part II, 9; ETA Sch VI, Part II, 32                                                                         XXXXX  XXXXX  XXXXX                                                                                File: 11860-02  XXXXX  XXXXX                                                                                Case: HQR0000018 Sch. VII 6; VIII 9 & 32 July 17, 1997 Thank you for your letter of August 28, 1996 (with attachments) in which you provided us with information concerning frames and lenses for prescription eyeglasses. ...