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16 November 1995 GST/HST Interpretation 11930-3[3]- Application of the GST to a Soccer Tournament Unedited CRA Tags ETA Sch V, Part VI, 12                                                                         File: 11930-3(DRM)                                                                         Doc: 1225                                                                         ss. 12/Pt VI/Sch. ... Venne Director Special Sectors GST Rulings & Interpretations c.c.: J. ...

. / 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. ... We note that the Department of Finance is aware of the above-described results and is currently examining issues with respect to the treatment of master trusts. […]. ... Paul Hawtin Special Provisions – FI Unit | Unité des dispositions spéciales- IF Excise and GST/HST Rulings Directorate | Direction de l'accise et des décisions de TPS/TVH LPRAB | DGPLAR Canada Revenue Agency | Agence du Revenu du Canada Tel. ...

As per our conversation of March 14, 2000 and April 11, 2000: •   the father has owned legal title to the farmland since at least XXXXX •   the partnership was formed at least XXXXX years ago •   there is no written partnership agreement •   the partnership operates under one name •   the farmland has been used by the partnership at least XXXXX years and is currently being used by the partnership in its farming operation •   the farmland will continue to be used by the partnership in its farming operation •   the income of the partnership is calculated as if the partnership were a distinct entity for Income Tax purposes •   the income derived and the expenses incurred with respect to the farmland are accounted for as partnership income and expenses •   there is no monetary sum involved in the transfer of the title of the farmland from the father to the father and son as joint tenants You have asked: 1. Will it be necessary for the son to register for the Goods & Services Tax on an individual basis? ... Since the interest in the land will be rolled from father to son at the adjusted cost base, should that amount, fair market value or some other value be used in reporting the acquisition of an interest in the land on the Goods & Services Tax return. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The following facts were provided in your letter: •   XXXXX; •   One of your XXXXX would like to purchase tax-free tobacco XXXXX; •   The tobacco is for resale for profit to fund XXXXX. •   A is a XXXXX under the authority of the XXXXX; •   A is not situated on a reserve pursuant to the Indian Act; •   B is a registered Indian who is the holder of an Indian Status card and is entitled to tax relief under section 87 of the Indian Act; •   Cs are Indian and non-Indian XXXXX; •   Between A and B there is mutual consent that B will act as an agent for A; •   Upon the request of A, B will purchase a supply of tobacco XXXXX; •   Once A is in possession of the tobacco, the tobacco will be resold XXXXX to Indian Cs XXXXX. ... Chesterman Aboriginal Affairs Unit Public Service Bodies & Governments Division Excise and GST/HST Rulings Directorate 2005/11/16 — RITS 61756 — Internet Sales to Indians ...

25 June 1997 GST/HST Interpretation HQR0000435- Expense Claims for Telemarketing Tickets Sold by a Charity Through an Agency Unedited CRA Tags ETA 169                                                                         File no. HQR0000435                                                                         June 25, 1997                                                                         XXXXX Dear XXXXX This is in response to a note dated November 22, 1996 sent by XXXXX of your office. ... This treatment is illustrated in the following hypothetical example: Example: Charity's gross revenues: 5,000 tickets sold @ $20 each = $100,000 Less expenses charged by telemarketing company: (   60,000) Subtotal (net profit) $  40,000 Less management fee charged by telemarketing company (   20,000) Amount kept by charity $  20,000 In this example, the $80,000 that the charity does not receive represents consideration paid to the telemarketing company for services provided, and this consideration has two components: $60,000 for expenditures plus a management fee of $20,000. ...

25 April 1997 GST/HST Interpretation HQR0000296[2]- Non-Resident Permanent Establishment and Security Requirement Unedited CRA Tags ETA 123(1); ETA 132(2); ETA 240(6)                                                                         File 11680-4(RMcK)                                                                         April 25, 1997 Gareth Llewellyn GST Policy & Procedures Policy, Procedures & Systems Business Registration Section Subject: Non-Resident Permanent Establishment and Security Requirement I refer to your E-mail message of September 19, 1996 concerning non-resident Permanent Establishment (PE) and changes to the security requirements. ...

29 January 2015 GST/HST Interpretation 162974- Supply of boat tours Unedited CRA Tags ETA 163(3), ETA 165, Indian Act: 87, TIB-039 GST/HST Administrative Policy — Application of GST/HST to Indians; Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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. ... STATEMENT OF FACTS We understand from your […][correspondence] that: 1. you are making this inquiry on behalf of your client who is an Indian (Footnote 1) under the Indian Act; 2. your client is […] registered for GST/HST purposes whose business activities consist of […], providing […] boat tours (“the boat tours”) by canoe and […](“the boat”), and operating a […] and convenience store on a reserve in [Province X]; 3. your client sells tickets for the boat tours from his convenience store that is located on a reserve; 4. a guide accompanies the participants on the boat tours that last for […] hours to […] hours. ... The boat tours go out around […] and return to [location A]. The water from which the boat tours depart is ocean and is not part of the reserve; 6. your client will provide lunch to the participants if requested, but the lunch must be ordered and paid for […] days in advance of the boat tour. […] shows the price for the lunch separately from the tour. ...

Statement of Facts •   The Company is registered for GST/HST XXXXX. •   The Company operates a silent on-line auction, XXXXX, available to the local population. ... The Company does not have any non-resident customers. •   There is no formal agreement between the Company and the vendors. •   The purchasers and vendors involved in these transactions are generally not GST/HST registrants. •   Purchasers submit a bid for an item by clicking on the item's corresponding link on the website. ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2005/07/27 — RITS 58794 — Application of GST/HST to Cranberry Juice ...

XXXXX It is our understanding from information provided in your memo, from University promotional materials, and from correspondence from XXXXX, that the five Camps consist of: •   Science Camp- co-hosted by the University Faculty of Mathematics and Sciences, all aspects of science presented as fun, educational and understandable, six modules: chemistry physics, biology, earth sciences, astronomy, mathematics and recreation and instruction; •   ArtMedia Camp- integrated art education and recreation program focusing on visual art, theatre and moving images using video technology and film elements; •   Drama Camp- drama and theatre production; •   Leadership Camp- personal, leadership and team skills development; and •   Nature Camp,- native habitat, ecosystems and wildlife exploration. ... XXXXX @ student). We appreciate that the all inclusive fee represents partial recovery for costs in providing all elements comprising the supply of instruction, however, this fact does not, in itself, preclude the University from making a single supply of instruction. ... After reviewing the summary of the provincial elementary curriculum for grades 1- 8 (1998) set out in attachments to your memo and on the provincial Ministry of Education web site, we agree with your conclusion that: •   Science Camp instruction follows the Science and Technology curriculum; •   ArtMedia Camp instruction follows the Arts curriculum; •   Drama Camp instruction follows the Art curriculum; •   Leadership Camp instruction follows the Health and Physical Education curriculum; and •   Nature Camp follows the Science and Technology curriculum. ...

The parties will not be considered to be partners but rather independent contractors operating jointly under an agreement. •   The landowner agrees that it shall not permit the installation of any equipment associated with the provision of laundry services in, on or at the building, by any party other than XXXXX •   The landowner will: •   supply at its own cost and expense: all utilities required in the operation of the laundry services including all water, gas, electricity, drainage, sewer outlets, ventilation systems, and janitor service to the premises; •   arrange for and pay the cost of all licenses, permits, provincial sales tax or other taxes which may arise as a result of providing the laundry services to the residents of the building; •   be responsible for the security of the building, premises and automatic laundry equipment used; •   keep the equipment and premises clean; •   carry insurance on the building and premises; and •   not interfere with XXXXX access to the premises in order to carry out its obligations under this agreement.  XXXXX will: •   connect at its own cost and expense the equipment to the electric, gas, water, and sewer connections in the premises and do all work needed for the installations of the equipment; •   carry insurance on the equipment; and, •   repair or replace the equipment when required. •   Title to the equipment shall at all times remain with XXXXX regardless of the nature of installation.   ... These factors are as follows: •   a contribution by the parties of money, property, effort, knowledge, skill or other asset to a common undertaking; •   a joint property interest in the subject matter of the venture; •   a right of mutual control or management of the enterprise; •   expectation of profit, or the presence of "adventure", as it is sometimes called; •   a right to participate in the profits; and •   most usually, limitation of the objective to a single undertaking or ad hoc enterprise. ...