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Section […] of the [LP2] Agreement more specifically explains that [LP1] will make its capital contribution to [LP2] by contributing $[…] cash firstly and fund the remaining balance of its capital contribution of $[…] by way of a set-off of the amount that will be payable on the second closing date by [LP2] to [LP1] pursuant to the […]. 5. ... Subsection […] of the [LP2] Agreement, under the heading […], includes distributions payable by [LP2] to [LP1] of $[…], representing a return of [LP1]’s Capital Contribution in the amount of the cash reimbursement which [LP2] is required to make pursuant to the […] for certain expenses incurred in the course of issuing Partnership interests (such amount hereinafter referred to as the […]). ... Factors to consider include, but are not limited to, the following: * the terms of the partnership agreement; * the nature of the action taken by the partner; and * the partner's ordinary course of conduct. ...

The Association is a national organization composed of the provincial associations […] from several [participating and non-participating] provinces […]. ... There are […] directors/ trustees and like officials listed on the Association’s 2012 T1235, Directors/Trustees and Like Officials Worksheet, […]. ... Pursuant to […], […] [the Board of Directors determines the location of the head office] 13. ...

The Corporation’s parking building is in very close proximity to [#] […] residential condominium buildings, which also have parking slips. ... There is a shared facilities agreement between the Corporation and the [#] neighbouring condominium corporations to acknowledge shared spaces with respect to the underground parking linked under the […] buildings. ... The Corporation’s only supplies are the supply of parking slips and bicycle storage units to residents of the [#] neighbouring condominium buildings. […]. ...

The Corporation, […], provides weekly summer day camps […][in July and August]. 9. ... The Corporation, […], provides an after-school program during the school year. 13. ... A supply of services made under the […] after-school program is exempt from GST/HST. ...

20 June 2017 Excise Ruling 184501- – Excise Duty Exemption – […][100% Canadian Wine exemption] Unedited CRA Tags EA2001/Part 4: 135(1),135(2)(a),135(3) Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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. ... To the best of [XYZ]’s knowledge, there is no commercially available apple concentrate produced in Canada. 13. […]. 14. ... Your letter refers to the Foley case and its similarity to your circumstances as stated in # 14 above. ...

21 January 2021 GST/HST Interpretation 202041- […] Taxation of First Nation Trust […] Unedited CRA Tags ETA Part IX, 123(1), Indian Act: Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 10th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 202041 Dear [Client]: Subject: [GST/HST INTERPRETATION] […] Taxation of First Nation Trust […] Thank you for your letter of [mm/dd/yyyy], concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to professional services supplied to a trust established by […] [a First Nation] […]. ... You asked that the Canada Revenue Agency (CRA) include a trust in the definition of “band-empowered entity” found in GST/HST Technical Information Bulletin B-039, Administrative Policy – Application of the GST/HST to Indians (TIB B-039). ...

STATEMENT OF FACTS We understand the following from your fax, your website […] and a telephone conversation of August 31, 2016: 1. […] (the Corporation) is a designer and manufacturer of supplies […] for the medical and scientific industry. ... The Corporation sells medical devices and hospital equipment to hospitals […] in Canada. 3. ... The Device is used by technicians, nurses, medical practitioners […]. 7. ...

10 June 2022 GST/HST Interpretation 236273- – [Adjustments to previous returns-] […] foreign currency conversion Unedited CRA Tags ETA Part IX, 159 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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 Place de Ville, Tower A, 11th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 236273 Dear [Client]: Subject: GST/HST INTERPRETATION [Adjustments to previous returns-] […] foreign currency conversion Thank you for your email received on [mm/dd/yyyy], where you requested our opinion concerning various requests made by […][a registrant]. ... [INTERPRETATION GIVEN] With respect to retroactively adjusting the method for converting the value of consideration, […], [a registrant] may request an adjustment to its previously filed net tax returns within four years after the later of the day the return was filed and the due date of the return. ...

28 August 2018 GST/HST Interpretation 175421- – Application of GST/HST to vehicle lease payments that include amounts attributable to insurance premiums […] Unedited CRA Tags ETA Part IX, 165, 221; ETA Sch V, Part VII Sec. 1 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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. ... The dealer forwards the entire insurance premium for the term of the lease and the certificate to the insurer but does not collect the insurance premium from the customer at that time. […]. ... You would like confirmation that the portion of the monthly lease payment attributable to the insurance premium […] (including the interest thereon) is exempt for GST/HST purposes. 2. ...