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CruiseCo estimates that the […][# of] Canadian cruise trips occurring in [yyyy][…] were sailing or at port in Canada for a total of [#] days. 6. ... CruiseCo estimates that the [#] cruise trips occurring in [yyyy] […][will be] sailing or at port in Canada for a total of [#] days. 8. ... Your [correspondence] did not specify the size of the […] ships entering Canada […]. 16. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The following is our understanding of the situation as presented in your letter: •   the charity is a registered charity within the meaning assigned under subsection 248(1) of the Income Tax Act and therefore a charity for purposes of the GST/HST under subsection 123(1) of the Excise Tax Act (ETA); •   the charity is registered for GST/HST purposes; •   the charity owns a commercial building and makes an election under section 211 of the ETA to make supplies of commercial leases subject to the GST/HST; •   as a result of having made the election, more than half of the total activities of the charity are taxable commercial activities; •   short-term accommodations, in a major city location, may be provided by the charity at a charge of $XXXXX per day. ... Yours truly, Debra Murphy Charities, NPO & Educational Services Unit Public Service Bodies & Governments Division Excise and GST/HST Rulings Directorate 2004/12/08 — RITS 45733 — Supply of Books with CD ROMs and/or Online Access in the Participating Provinces ...

6 February 1996 GST/HST Interpretation 11650-7[3]- Input Tax Credit Entitlement on Removal Expenses Unedited CRA Tags ETA 169; ETA 170; ETA 175                                                                         11650-7 (pl)                                                                         Sections 169, 170 & 175 XXXXX February 6, 1996 Dear XXXXX Thank you for your facsimile transmission dated December 13, 1995, in which you request a GST interpretation of sections 169 and 175 of the Excise Tax Act (the "ETA") in reference to the Input Tax Credit entitlement on the reimbursement by a registrant of the GST paid on removal expenses. Statement of Facts: In your facsimile you provide the following facts for our consideration: •   A registrant transfers an employee from one work location to another and agrees to reimburse the employee for the moving costs (including the GST); •   The employee purchases a new residence from a builder which GST is charged and paid for by the employee; •   The registrant reimburses the employee for all the moving costs: •   The amount reimbursed by the registrant to the employee for the land transfer tax on the purchase of the new residence is not considered to be a taxable benefit to the employee under the Income Tax Act. ... Jones Director General Applications Division GST Rulings and Interpretations GAD #: 2636 (GEN) c.c.: M. ...

Interpretation Given Our administrative policy P-125, " Importer and ITC Entitlement " discusses who is the de facto importer. ... This interpretation is consistent with our administrative policy regarding the place of supply rules (P-078R, " Meaning of the phrase delivered or made available in (or outside) Canada to the recipient "). ... Yours truly, Catherine Séguin General Operations Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate c.c.: Dave Caron, Manager, General Operations Unit Encl.: P-125, " Importer and ITC Entitlement "; P-078R, " Meaning of the phrase delivered or made available in (or outside) Canada to the recipient " Legislative References: sections 165, 212 of the Excise Tax Act NCS Subject Code(s)- I 645-3, 650-1, 670-4 ...

Subsection […] of […][Regulation X under Provincial Act B] states that […][the organizations] set out in [...] of that Regulation are designated as [Administrators] under subsection [...] of […][Provincial Act B]. 5. Neither [Provincial Act B] nor its Regulations define the terms ‘affordable housing’ or ‘market affordable housing’. 6. […] of [Provincial Act B], section […] states: “rent-geared-to-income assistance” means […]; [Administrators] 7. ... To meet local housing needs, [Administrators] use […] funds to establish, administer and fund housing […] programs and services. ...

Scenario 2: •   The NRs themselves, in their own right, or through representatives- employees or independent contractors-, acquire motor vehicles in Canada directly from Candeal or at auctions, for re-supply on the U.S. market. •   Although the NRs do not maintain a presence in Canada (i.e., a permanent establishment), it is possible for the NRs to lease office space for the purposes of purchasing motor vehicles in Canada. ... For your information, I have enclosed a GST/HST publication entitled " Doing Business in Canada ", which provides further details on registration. ... Please find enclosed GST/HST Policy Statements P-208, entitled " Fixed Place of Business " and Policy Statement P-051R, entitled " Carrying on Business in Canada ", that will provide you with more information on whether a permanent establishment exists in Canada, through which a person makes supplies. ...

The housing development was built with funding from the […] ([…][Crown Corporation]). […] 4. […]. 5. ... Our records indicate that [Organization A] was incorporated […] on [mm/dd/yyyy]. ... This would include when [Organization A] […] is no longer receiving government funding. ...

Statement of Facts Our understanding of the facts is as follows: •   The Product comes in XXXXX-gram re-sealable pouches. •   The Product is available in XXXXX varieties: XXXXX. XXXXX. •   The Product packaging indicates an expiry date and that XXXXX. •   There is no XXXXX added to the Product. •   The Product label states: XXXXX. •   The Product is placed near XXXXX in grocery stores. •   Each variety has XXXXX listed on its' packaging. ... Snack mixtures usually have the following characteristics: •   Consumers commonly view them as snacks. •   Their ingredients are ready to eat; no further processing is required. •   The ingredients have been combined before the product is sold. •   The main ingredients remain separate and distinct from each other and are not bound into one whole. •   The main ingredients are often coated with a savoury seasoning such as salt or barbecue flavouring. •   They are eaten by the handful or as individual bite-sized pieces without utensils. •   They are usually sold in pouch packs or bags, from bulk bins or in clear plastic containers. ...

XXXXX provides the following supplies: •   Intranet design and hosting •   Web site design and hosting •   Maintenance and programming for the sites •   Technical support for the sites •   Computer hardware and software sales •   On-site consulting and training XXXXX clients are in the United States and in Canada, its office is located in XXXXX, XXXXX and the Internet server that XXXXX uses to host the sites is located in XXXXX, United States. ... Interpretation Requested What is the tax status of the supplies that XXXXX provides in the following situations: •   Client is located outside North America, server in XXXXX, development work done in XXXXX. •   Client is in the United States, server is in XXXXX, development work done in XXXXX. •   Client is located in Canada outside XXXXX, server is in XXXXX, development work done in XXXXX. •   Client is located in XXXXX, server is in XXXXX, development work done in XXXXX. •   Client is a multinational, with offices in the United States and Canada (including XXXXX), head office is in XXXXX. ... Programming involves three levels: •   Purchasing "off the shelf" software to use on the client's site. •   Modifying existing software to meet clients' needs. •   Programming from scratch for a customized solution. 2. ...

The Partnership’s representative states that the agreements have been assigned to the Partnership; however, no documentation was provided to this effect. 14. […][Based on information provided]:(Footnote 1): * The Partnership owns the […] assets […], and [ACo] had prior contractual and business relationships with the counterparties. […] assets are held by the Partnership, […] revenue is reported in the Partnership. * With respect to […][the Supply] to [CCo], the Partnership is the […][person] [who] would be the party to invoice and collect the tax. However, since [CCo] and [ACo] had a previous relationship which was continued […], [ACo] is billing [CCo]. 15. […][Your submission did not include] any agreement authorizing [ACo] to act as agent of the Partnership […]. […] [ACo] [does not] receive any remuneration from the Partnership for services of acting as its agent. 16. ... FOOTNOTES 1 […]. 2 […]. 3 A completed Form GST506 alone is not sufficient evidence that an agency relationship exists between parties. ...