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Where this is not determinative of the place of supply, the supply may be regarded as being made in a participating province where: •   the place of negotiation for the supply is located in Canada, if the Canadian element of the service is to be performed primarily in the participating provinces. The supply of the service is considered to be made in the participating province in which the greatest proportion of the Canadian element is to be performed; or •   the place of negotiation for the supply is located outside Canada, if all or substantially all of the service is to be performed in Canada, and it is to be performed primarily in the participating provinces, the supply is considered to be made in the participating province in which the greatest proportion of the services to be performed in the participating provinces are to be performed. ... Legislative References: ETA: 123(1); 142; 144.1; 165(1) & (2); IX/V/1; IX/I/1; NCS Subject Code(s): 11875-1 Policy paper: P-077R- SINGLE MULTIPLE SUPPLIES P-078R- MEANING OF THE PHRASE "DELIVERED OR MADE AVAILABLE IN (OR OUTSIDE) CANADA TO THE RECIPIENT" P-159R- MEANING OF THE PHRASE "REASONABLY REGARDED AS INCIDENTAL" P-160- MEANING OF THE PHRASE "WHERE A PARTICULAR PROPERTY OR SERVICE IS SUPPLIED TOGETHER WITH ANY OTHER PROPERTY OR SERVICE" c.c.: P. ...

The following information was provided in your letter and telephone messages: XXXXX  is registered for GST/HST purposes XXXXX •   XXXXX  is engaged in the commercial activity of providing access to a software application called XXXXX through the internet for a fee ranging from $XXXXX  The software application is stored on servers located in XXXXX a and is accessed through the website "XXXXX. ... The rate charged is dependent upon the sample exam the client requests to access. •   The client must pay the access fee prior to receiving access to the desired exam. ... Once the credit card charge has been accepted by the appropriate clearing agency XXXXX issues a password to the client which allows access to the requested exam. •   While some of XXXXX clients are residents of Canada, a significant number are non-residents for purposes of the Excise Tax Act (the "Act"). ...

20 November 2002 GST/HST Interpretation 41962- Whether Executors' Fees are Subject to GST Unedited CRA Tags ETA 123(1) taxable supply; ETA 123(1) commercial activity; ETA 123(1) business; ETA 123(1) office Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXX Case Number: 41962File #: 11750-2November 20, 2002 Subject: GST/HST INTERPRETATION Whether Executors' Fees Are Subject to GST Dear XXXXX Thank you for your letter of XXXXX (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the fees paid by an estate to three executors appointed pursuant to the will of a deceased individual. ... You submit that based on the definitions of "taxable supply", "commercial activity", "business", and "office" in subsection 123(1) of the Excise Tax Act (the "ETA"), the definition of "office" in subsection 248(1) of the Income Tax Act, GST Question & Answer #3d.21, and a finding that in the cases of both the freelance bookkeeper and the lawyer the compensation would be income from an office under the Income Tax Act, the fees would not be subject to GST. 7. In your view the position of the CCRA outlined in GST Question & Answer #3d.21 is not clear with respect to the freelance bookkeeper and the lawyer because the bookkeeper was appointed executor due to XXXXX past working relationship with the deceased individual (i.e. ...

The following are some of the factors that apply to Product A and B: •   If a product identifies itself as a 'supplement', 'dietary supplement', 'food supplement' or similar terminology, this is an indication that the product is consumed for the purpose of enhancing or improving a person's state of health and not as a food, beverage or ingredient. ... As noted above, products that meet the 'nutritional supplement' labelling and nutritional requirements of the Food and Drugs Act are zero-rated. •   Product advertising, whether through print or electronic media, that includes a claim related to purported beneficial effects (as mentioned above) indicates that the product is intended to be consumed for purposes other than as a food, beverage or ingredient. Product B XXXXX which indicates that the product is intended to be consumed for a purpose other than as a food, beverage or ingredient. •   Products that emphasize the purity or superior quality of a particular nutrient and relate that nutrient to a therapeutic or beneficial health effect or enhanced performance or physique are not considered to be consumed as a food, beverage or ingredient. ...

In addition, paragraph 154(2)(a) of the ETA provides that the consideration for the supply of wine includes any "... duty... imposed under an Act of Parliament... that is... payable or collectible by the supplier, in respect of that supply or in respect of the production, importation, consumption or use of the property... ... Yours truly, Susan Kissner Specialty Tax Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate Legislative References: •   Excise Tax Act (ETA): subsection 123(1) definitions of consideration, supply; sections 133; 134; 154; 165;•           Excise Act, 2001 (EA1) June 13, 2002 Royal Assent / July 1, 2003 implementation date): section 2 definitions of alcohol ii1, beer, spirits, wine; Part IV (Alcohol): sections 59-158, subsection 135(3), 138(2); sections 136, 137, 139.•       Excise Act R.S., c. ...

There are two distinct situations: •   The clergy makes no specific request for payment for performing a funeral service, however, the family decides to make a donation through the funeral home that is providing the funeral arrangement. The payment by the funeral home is done as a service to the family and no money is retained by the funeral home for this service; and •   There is an amount specified by the clergy, which is then forwarded, again, through the funeral home to the Church or clergy. ... 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. GST/HST Rulings Directorate 5th floor, Tower A, Place de Ville 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 212366 Business Number: […] Dear [Client]: Subject: GST/HST RULING Supply of hay for horses Thank you for your correspondence of [mm/dd/yyyy], concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to supplies of hay for horses used for trail rides, racing, and dressage. ... STATEMENT OF FACTS We understand the following: 1. […] (the Company) is a business located in [City, Province]. 2. ...

. / 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. ... INTERPRETATION REQUESTED You would like to know the Canada Revenue Agency position concerning the application of the GST/HST to the supply, by a placement agency, of nursing personnel to nursing homes and hospitals (the health care facilities) further to the decision A-Supreme Nursing & Home Care Services Inc. v. ... If yes, who assumes the responsibility – the agency or the health care facility? ...

. / 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 currently making supplies of short-term accommodation of a home […], in […][a non-participating province A]. 2. ... In [mm/yyyy], [the Company] began to send you invoices labelled as […] for GST amounts on prior transactions. ...

Accordingly, our comments below are limited to those circumstances. […]. ... A CSP receives payment in the form of [cryptoasset] based on the estimated revenue calculation […]. ... In a FPPS payment arrangement, generally the Operator bears the risk associated with mining a block […]. ...