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STATEMENT OF FACTS Based on the information you provided, our understanding of the facts is as follows: Parties involved: * […] (Vendor) – sets up ATM bank machines (i.e., sells equipment & related software licences), * […]([…][X]) – assignor and subsequently lessee, * […] (Lessor), a non-depository short term credit institution that provides primary equipment financing through leases – assignee and subsequent lessor All parties are registered for GST. Facts: * [X] enters into an “Acquisition Agreement” to acquire equipment & software licenses from the Vendor. * [X]’s acquisition of the equipment does not include the purchase of any software which is licensed to [X] by the Vendor. ... It is not clear how this particular taxable supply was accounted for, since the full Equipment Lease Agreement [#] was not submitted […]. […] […] [ABC] has referred to section 165 of the ETA to say that “every recipient of a taxable supply made in Canada” shall pay GST/HST based on the “value of the consideration for the supply”. ...

In sum, [to be considered] an “in vitro diagnostic test” […][for GST/HST purposes]: * The test is for use in the diagnosis of a disease in humans and; * The test contains at least one of the four substances listed above. ... The Oxford Concise Medical Dictionary defines “diagnosis” as “the process of determining the nature of a disorder by considering the patient’s signs and symptoms, medical background, and – when necessary – results of laboratory tests and X-ray examinations”. ... Yours truly, Kassandra Leonard Health Care Sectors Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 [...] 2 [...] 3 [...] 4 […] 5 […] ...

The charge to the individual is $[…]. * Complex medication review where the individual takes [#] to [#] medications and has [#] to [#] medical conditions. The charge to the individual is $[…]. * Follow-up appointment after completion of the medication review. ... The charge to the individual is $[…]. * Follow-up appointments in a package of [#] appointments over a […] period. ...

EXEMPT $         0 G.S.T. (R.......) $  2,415 Total $36,915 Less Deposit $- ___ Balance Owing on Delivery $36,915 A typical worksheet would be as follows: Lessee Deemed sale of used vehicle $  10,500 GST collected $   735 [i] (1) Deemed Payment re new vehicle $- 10,500 GST collected $- 735 [ii] (1) Net Cash Received by Lessee $           0 Dealer Sale of New Vehicle Base Cost $  45,000 Licence $           0 Air Conditioning $ 0 $  45,000 GST Collected $3,150 [iii] (1) Deemed Purchase of Used Vehicle $-10,500 GST Paid  -     735 [iv] (1) Net Cash received by dealer $ 36,915 Lessor Deemed purchase of used vehicle $-10,500 GST paid $- 735 [v] (1) Deemed payment by lessee $  10,500 GST collected $  735 [vi] (1) Net Cash to Lessee $           0 Purchase of New Vehicle Base Cost $   45,000 Licence $            0 Air Conditioning $ 0 $   45,000 GST Paid $ 3,150 [vii] (1) Deemed sale of used vehicle $- 10,500 GST collected $- 735 [viii] (1) Net Cash to Dealer $   36,915 In the above example, it is assumed that the lessee owns a vehicle with a fair market value of $10,500 and wishes to lease a new vehicle worth $45,000. ...

Shares") at a price of $[...] per share (max. [#] shares / $[...]). ... Management Fee and a [...] Service Fee [...]. The Service Fee is equal to [...]% [...] of the [...] Shares (subject to certain adjustments) held [...] by the Clients [...] [...] the Agreement and the Prospectus both state that the Investment Manager is required to pay to the Dealers a service fee [...] based on the number of [...] ...

The supplies made by the Corporation to owners and lessees of the units include the following: •   Electricity •   Repairs and maintenance •   Groundskeeping •   Garbage removal •   Insurance •   Management fees •   Water and sewer •   Snow removal and street cleaning[.] 6. ...

1 March 1996 GST/HST Interpretation 11650-2- Approval and Acceptance of Annual Blended Rates for the Purposes of Claiming Input Tax Credits (ITC's) Under the Excise Tax Act (the Act) Unedited CRA Tags ETA 169; ETA 141.01                                                                         File #: 11650-2(on)                                                                         c.n. 2486(GEN)                                                                         s. 169 & 141.01 XXXXX March 1996 Dear Sir: I refer to your letter of June 8, 1995, requesting the approval and acceptance of annual blended rates for the purposes of claiming input tax credits (ITC's) under the Excise Tax Act (the Act). ...

15 October 1998 GST/HST Interpretation HQR0001016- Penalty and Interest on Closely Related Group of Joint Filers MEMORANDUM TO: Brian Paynter Returns & Payments Assessments & Collections Branch FROM: David Crawford General Operations Unit General Operations & Border Issues Division Subject: Penalty & Interest on closely related group of joint filers This memo is in response to your e-mail of December 19, 1997 addressed to Pat McKinnon. The facts of your question are: •   One member of a closely related group of joint filers under ss. 228(7) is audited and the refund that the member claimed is reduced or negated. •   If that refund was applied to a debit on a related account, the "invalid" credit reverses back to the first account and causes a debit on the second account to attract penalty and interest. •   The question is who should be assessed and liable for penalty and interest? ... RESEARCH •   Forms GST 303A & GST 303B •   Policy P-140 •   OFFSET OF TAXES BY A REFUND OR REBATE (GST) REGULATIONS •   Q & As from database •   explanatory notes from GST database ...

Our understanding of the facts is as follows: •   The College is a public college as defined in subsection 123(1) of the Excise Tax Act (ETA). ... For periods prior to January 1, 1997, the College would have been considered a charity for purposes of the ETA. •   The XXXXX has entered into an agreement with the College to purchase apprenticeship training courses for delivery to specified third parties (apprentices) according to training standards established by the XXXXX. •   XXXXX •   XXXXX. •   XXXXX §   XXXXX §   XXXXX §   XXXXX. •   XXXXX. •   The College has filed an election under section 6 of Part III of Schedule V to the ETA to deem the supply of Apprenticeship courses to be taxable for GST/HST purposes. •   The courses provided by the College under the Apprenticeship program do not have equivalency for credit courses. •   There are situations where a student may be granted exemption for a credit course in a degree or diploma program, but this is evaluated on a case-by-case basis. ...

The following documents were submitted for our consideration: * Form GST386, Rebate Application for Foreign Conventions, on which [Company A], a non-resident located in […][Country Z] claimed a FCTIP rebate of $[…] as the organizer of a foreign convention. ... The invoices for the hotel accommodations were not included. * A letter from [Company A] describing the purpose of the meetings. ... The program agenda indicates that the following activities took place over the period from [mm/dd] to [mm/dd/yyyy]: * Arrival in [City 1] on […] [Day 1] * [Day 2] […] [describes included tours, networking lunch and dinner]. * [Day 3] […] [describes included tours, networking lunch and dinner]. * [Day 4] Travel to [City 2]. […] [describes included tours, networking dinner]. * [Day 5] […] [describes included tours, award dinner]. * [Day 6] Departure from [City 2] […]. […][Interpretation Given] In order for an event to qualify as a foreign convention for purposes of the FCTIP, it must first be established that the event is a convention for GST/HST purposes. ...