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1 October 1996 GST/HST Interpretation 11640-3[9]- Application of the GST to Telemarketing Services Supplied by a Non-resident Corporation Unedited CRA Tags ETA Sch VI, Part V, 5; ETA Sch VI, Part V, 7 XXXXX XXXXX XXXXX XXXXXATTENTION: XXXXX Telephone #: (613) 954-4585 Fax #: (613) 990-1233File #: 11640-3(glr) HQR0000126 s. 123, 132, 142 Sch. ... XXXXX requested a review of his proposed interpretation letter to XXXXX I understand that: •   XXXXX is a non-resident corporation incorporated in XXXXX[.] •   XXXXX provides XXXXX services on behalf of XXXXX throughout XXXXX[.] •   XXXXX contracts with a Canadian company, XXXXX located in XXXXX, to provide telemarketing services. •   These telemarketing services consist of XXXXX contacting people throughout XXXXX to solicit orders for XXXXX[.] When telemarketing calls are successful, they are relayed to the appropriate office in XXXXX and the applicable XXXXX is carried out by the operator responsible for that market. •   When XXXXX invoices XXXXX for the supply of the telemarketing services, the totals are shown in XXXXX XXXXX pays for these services in XXXXX[.] •   Although XXXXX has an administrative office in XXXXX all the services are performed in XXXXX and all revenue is generated in XXXXX[.] ...

. •   How does a particular APS treat the subject of upgrades? •   Is there a separate agreement between the builder and purchaser detailing the nature and cost of upgrades? ... Cahill Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate Encl.: Legislative References: ETA s 123(1), s 234(1), s 254, ss 262(2) References: Section 19.1 " Real Property and the GST/HST " of the GST/HST Memoranda Series Section 19.3.1 " Rebate for Builder-Built Unit (Land Purchased) " July 1998, of the GST/HST Memoranda Series CCRA Guide " GST/HST New Housing Rebate " rev. 2001 XXXXX XXXXX XXXXX XXXXX CCRA Policy Paper P-077R rev. Apr./98 " Single and Multiple Supplies " CCRA Policy Paper P-052 issued Mar./93 " Amounts Eligible for Section 254 ["] XXXXX NCS Subject Code(s): I-11870-4 b.c.c.: Quality Assurance ...

1 August 1996 GST/HST Interpretation 11645-3[1]- The Application of the Goods and Services Tax (GST) to Canadian Goods Returned to Canada Unedited CRA Tags ETA 142(1)(b); ETA 252(1); ETA Sch VI, Part V, 1                                                                         Telephone #: (613) 954-5124 Fax #: (613) 990-1233 11645-3 (crl)  Sch. ... Jones Director General Applications Division GST Rulings and Interpretations Policy and Legislation Branch GAD # 2971 (Genl) c.c.: R. ...

3 January 1996 GST/HST Interpretation 11910-5[4]- Tax Status of Post-secondary Institutions Unedited CRA Tags ETA 123(1) public college; ETA 123(1) university                                                                         File: 11910-5(DRM)                                                                         Doc: 1195                                                                         Subsection 123(1) XXXXX January 3, 1996 Subject: XXXXX XXXXX I refer to your memorandum of March 7, 1995 to Joanne Houlahan, concerning the tax status of XXXXX[.] ... Venne Director Special Sectors GST Rulings & Interpretations c.c.: J. ...

1996 GST/HST Interpretation 11715-5- Summarize of Current Policy With Respect to the Application of GST to Voluntary Payments                                                                         TELEPHONE 954-8585                                                                         FACSIMILE 990-1233                                                                         11715-5(sn) XXXXX January 1996 Dear Ms. ... Jones Director General Applications Division GST Rulings & Interpretations          896(REG) Mitch Bloom (signoff) c.c.: Application Team ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The trade confirmation identifies: •   The underlying product; •   The deal type; •   The description i.e., what the buyer pays and receives; •   Seller and Buyer information, including commission rate; and •   The party that executes the trade (i.e., the individual broker). 5. ... Yours truly, Kirk Moore Financial Institutions Unit Financial Institutions & Real Property Division Excise and GST/HST Rulings Directorate 2007/02/09 — RITS 76905 — XXXXX Music Cards ...

Pursuant to the terms of the [...], ManageCo is entitled to a fee of [...], plus an amount equal to the [...] ... Fees Payable to ManageCo will be calculated and payable [...] based on the [...] of TrustCo calculated at [...] during [...]. The management fee will be paid in cash. 5. [...] Fee is defined in the Prospectus to mean the [...] fee that ManageCo pays to the registered dealers [...] for each [...] held by clients of the registered dealer. 6. ...

The following information was taken from your letter and our subsequent telephone conversations: •   XXXXX[.] •   XXXXX[.] •   The software that is available for sale is developed by XXXXX at his establishment in XXXXX and is stored on his web site on a server located in XXXXX. •   Potential clients may download a sample version of the software for evaluation purposes. The sample version has limited capabilities and is provided free of charge to assist the user in determining whether to purchase the fully functional version. •   To obtain a fully functional version of the software the client must first download the sample version from XXXXX The client must then make payment to XXXXX by providing credit card information and authorization on the web site. ... 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... ...

Cost less Residual)   10,350.00 Finance Charge per month (Finance Base x Money Factor)        109.35 Depreciation Charge per month (Depreciation Base / Term)        215.63 Lease Payment per month (Finance Charge + Depreciation Charge)        324.98 Step 2: Re-calculation of lease payment (for GST purposes only). ... Cost less Residual)                nil * Finance Charge per month (Finance Base x Money Factor)          63.70 Depreciation Charge per month (Depreciation Base / Term)                nil * GST Base (Finance Charge + Depreciation Charge)           63.70 GST per month (GST Base x 7%)             4.46 * Note: The proposed subsection 153(4) trade-in approach does not provide for negative amounts. ... Jones Director General Operations and Border Issues Division GST Rulings and Interpretations Directorate GAD #: 3092 (GEN) c.c.: M. ...

It states that trailing commissions are paid by […] ([…] a mutual fund company) to the Dealer for the delivery of services you receive. ... Operating charges of $[…] plus taxes of $[..]; and b. Trailing commissions of $[…]. 3. ... You also wish to know if […], as an investor, is entitled to a refund of the GST/HST equal to the amount paid by the funds held […]. ...