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The enclosed Departmental Policy Paper P-215, " Determination of Whether An Entity Is A 'Non-Profit Organization' For Purposes Of The Excise Tax Act ", provides further explanation of the term non-profit organization. ...

Warren, Rulings Officer, Real Property Unit, GST R & I, letter to XXXXX XXXXX (HQR0001063, October 2, 1998)D. Hooley, Senior Technical Analyst, Real Property Unit, Excise & GST/HST Rulings, Email message to C. ...

Yours truly, Susan Eastman Municipalities and Health Care Services Unit Public Service Bodies and Governments Division c.c: Michel Guay Susan Eastman Legislative References: 9/II/VI & 32/II/VI & 6/VII NCS Subject Code(s): 11783-1 ...

In your submission you provide the following example: Consumer Billing Distribution service charge $400.00 Electricity (charged on behalf of retailer) $500.00 Total consumer billing $900.00 + GST ($63.00) Distributor's accounts Cost of power acquired by the distributor $490.00 + GST ($34.30) It is our understanding that you propose to treat the GST in the following manner:-    the distributor will issue an invoice to the consumer that will include a charge for distribution services in respect of the electricity ($400.00) and an amount charged on behalf of the retailer in respect of the electricity supplied by the retailer ($500.00);-    the distributor will charge GST on the total amount of the invoice ($900.00) which includes the amount charged on behalf of the retailer. ...

In that leasehold strata plan, this amount ranges from approximately XXXXX % of the purchase price of a strata lot to XXXXX %. ...

XXXXX's client may be: •   a resident supplying event admissions to either residents, non-residents, or both; or •   a non-resident supplying event admissions to either residents, non-residents or both. ...

Section 1 of Part I of Schedule IX to the Act defines the "place of negotiation" of a supply to be "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works... ... A copy of Policy Statement P-222 Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of the Excise Tax Act " is also enclosed for your reference. ...

. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. ... Each Concurrent Lease will commence on the lease date set out on the Asset Lease and ends "... ...

The Head Lease has the following terms relevant to the issues of this interpretation: (a) The XXXXX Assets will remain property of, and title to the XXXXX Assets will remain in, the Utility; XXXXX (b) The City shall retain possession and quiet enjoyment of the XXXXX Assets until the end of the lease term; XXXXX (c) The Head Lease calls for a lease term of XXXXX years; XXXXX (d) The Utility has the right of early termination after XXXXX years of the lease term has lapsed; XXXXX (e) The City agrees to pay an annual rent for the XXXXX Assets and the parties acknowledge that the GST is applicable to the rent payments; XXXXX (f) The City is granted the right to prepay XXXXX % of the total annual rent for the lease term at the present value of the annual rent over the lease term using a discount rate of XXXXX % (note, this right was exercised by the City); XXXXX (g) The Utility acknowledges and agrees that the City shall be permitted to assign or sublet the XXXXX Assets to another party to operate as contemplated in XXXXX (h) Where the City assigns or sublets the Head Lease or the XXXXX Assets, such assignment or subletting shall not merge with the Head Lease; XXXXX and (i) The "lessee[City] agrees that the XXXXX Assets remain the property of the Utility notwithstanding the manner in which or the degree to which the same may be attached or affixed to realty"; XXXXX 3) The City and the Utility entered into the Sublease dated XXXXX (Sublease) whereby the City, as lessor, subleased the XXXXX Assets to the Utility, as lessee. ...

However, as the terminology and rules related to the ownership of the copyright may differ between the U.S. and Canada, Can Co. has established a XXXXX % owned subsidiary based in XXXXX to serve its U.S. clients. ... In accordance with this provision, a supply of IPP is considered to be made in a province if the place of negotiation ("place of negotiation" of a supply refers to "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works, or to which that individual ordinarily reports, in the performance of the individual's duties in relation to the activities of the supplier in the course of which the supply is made... ...