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The Property comprises a [#]-room […] bed and breakfast, including, among other things, a […] restaurant, multiple large conference rooms, and a garden and guest parking. ... On [mm/dd/yyyy], […] (the Corporation) was incorporated under […][Province A]’s Business Corporations Act. ... Smith Manager, Special Provisions – General Unit Excise and GST/HST Rulings Directorate ...

There are several courts which have written useful judgements on this topic including: •   Wiebe Door Services Ltd. v. ... A-531-85) [1986] 2 C.T.C. 200, [1986] E.T.C. 2132, 86 D.T.C. 5025, dated January 1, 1986; and, •   Castlegar Taxi (1988) Ltd. v. ... Other factors mentioned in the Castlegar case included: •   drivers being subject to direction and disciplinary action; •   company determining when the drivers work; •   company holding taxicab licences; •   company dispatching business to drivers; •   company reserving right to terminate relationship either for cause or arbitrarily; •   company setting dress code for drivers; •   drivers not being permitted to allow free rides and drivers not being allowed to carry out own errands except in course of delivering passengers to destination; •   company policy governing the driver's use of the vehicle between passengers hiring of the cabs; and •   drivers being required to make daily filings of fares taken. ...

6 February 1997 GST/HST Interpretation 11950-1- Cemetery Plots Unedited CRA Tags ETA Sch V, Part VI, 25                                                                         File #11950-1                                                                         Reference 25/VI/V                                                                         February 6, 1997 XXXXX This concerns your memorandum of November 27, 1996, concerning the application of GST to supplies made in connection with human burial in XXXXX XXXXX[.] ...

16 April 1997 GST/HST Interpretation HQR0000638[2]- Application of the GST on the Supply of Teachers Unedited CRA Tags ETA Sch VI, Part V, 5; ETA Sch VI, Part V, 7; ETA Sch VI, Part V, 23; ETA 142(1)(g)                                                                         April 16, 1997                                                                         11640-2(RMcK)                                                                         XXXXX Dear XXXXX This refers to your facsimile of April 11, 1997 concerning the services to be provided by you to XXXXX in the recruitment XXXXX of teachers for XXXXX schools. ...

27 February 1997 GST/HST Interpretation HQR0000151- Tax on Licenses Issued by the Board Unedited CRA Tags ETA Sch V, Part VI, 20(c) XXXXX Rits #: HQR0000151 XXXXX File #: 11847-6                                                                         February 27, 1997 Dear Sir, Thank you for your letter of March 21, 1996 (with attachments) concerning the application of the Goods and Services Tax (GST) to the transaction described below. ...

Facts •   XXXXX XXXXX[.] •   XXXXX provides advisory services exclusively to its two subsidiaries; XXXXX[.] •   During 1994 with respect to advisory services from the XXXXX and XXXXX[.] •   The two subsidiaries are incorporated under the XXXXX and operate under the XXXXX as venture capital funds deriving their revenue from interest, dividends, fees, et cetera. •   All the issued and outstanding common shares of XXXXX are owned by XXXXX[.] •   XXXXX[.] •   According to the XXXXX offering memorandum, investors who subscribe for one or more bonds may qualify for Canadian permanent resident status along with their spouse and dependents. Investment is required for a minimum number of years.      Also according to the memorandum, the "main purpose of the Fund is to provide equity or loan capital to establish, purchase, or maintain eligible businesses or commercial ventures,..."[.]      XXXXX[.] •   As established in a telephone conversation with XXXXX, on August 17, 1995, XXXXX is not and has not been charging GST on its supplies of advisory services to the funds. ...

. / 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. ... [Corporation A] is registered for GST/HST purposes effective [dd/mm/yyyy]. 3. […] 4. […]. 5. […][Corporation A carries on various activities, including making exempt supplies to the tenants and residents of its housing sites and long-term care facilities]. 6. […]. 7. […]. 8. […] 9. ... For more information, see GST/HST Memorandum 19.2.2, Residential Real Property – Rentals. ...

Although the policy provides that GST returns will not be adjusted to account for unclaimed input tax credits (ITCs) that do not offset an increase in tax liability, it is our view that the Department may wish to exercise discretion pursuant to subsection 296(2) of the Excise Tax Act [.] Given that Policy P-149 " Administrative Policy Regarding Adjustments to the GST Return " was in place prior to April 1995, the client should have been advised at that time to claim the ITCs in the next reporting period as opposed to advising the client five months later. ... Vallières Chief Program Policies & Procedures Section Small & Medium Business Enterprises Division MacDonald Building 123 Slater, 8th floor             D. ...

Interpretation Requested We understand that you are proposing to enter into an agreement with the XXXXX XXXXX (the "Township") that would refer to activities such as: •   Water chlorination, quality testing, and distribution to homes; •   Sewage removal involving pumping sewage to specific lagoons and chemically treating the sewage before it is released into the environment; •   Snow removal from roadways and residents' driveways; •   Maintenance of parks and common areas, consisting of grass cutting, planting flowers, maintaining flower beds, etc.; •   Street lighting of main thoroughfare; •   Cleaning adjoining canals, including weed control; •   Maintenance of a swimming pool; •   Maintenance of tennis courts; •   Maintenance of a recreation centre; and •   Maintaining the roads within your residential area. ...

The following information has been provided in your letters, from the web-sites of XXXXX and during our telephone conversations XXXXX: •   XXXXX. •   The XXXXX receives funding from the XXXXX. •   The office of the XXXXX is not located on a reserve. •   XXXXX. •   The members of the XXXXX are elected and are responsible for their operating budget XXXXX. •   For the year XXXXX a motion was passed by the XXXXX designating the office of XXXXX as the finance and administration unit in charge of budgets, accounting, supporting document retention, monthly financial statements, etc. •   The XXXXX is incorporated under the Laws of Ontario as a corporation XXXXX. •   The XXXXX is overseen by a Board of Directors representing the XXXXX. •   The objective of the XXXXX. •   The office of the XXXXX is not located on a reserve. XXXXX. •   The XXXXX elects the directors of the XXXXX from the members of the XXXXX. ... Chesterman Aboriginal Affairs Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2005/06/30 — RITS 57840 — Supplies to Partnership ...