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Example 1 A business is made up of the following assets, with the following values (no other assets are required or used in operating the business): Real property (factory): $100,000 Equipment: $  70,000 Inventory: $  15,000 Intellectual Property: $  15,000 Total: $200,000 If the purchaser buys the Equipment and Inventory from the Vendor for $85,000 can the purchaser use section 167 if it leases the property in the following situations: Situation 1 Purchaser enters into a one-year lease with the Vendor with the monthly rent being $5,000. ... If value of property is being used: Yes (185/200 = 92.5%) If value of lease is being used: No (85/100 = 85%) If present value of lease stream is used (assume ($50,000): Yes (135/150 90%) Situation 2 Purchaser enters into a twenty-year lease with monthly rent of $1,000. ... Example 4 It is always a question of fact whether the "substantially all " test is met. ...

15 September 1995 GST/HST Interpretation 11845-2[9]- The GST Status of the Supply of the Pesticide Unedited CRA Tags SOR/91-39 Sch 1(4)                                                                         11845-2(MB) Doc: 2438G Ref: Ss 1(4) of Agri & Fish Regs.                                                                         ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... For example, as long as it is fair and reasonable in a particular situation, the supplier could allocate the delivery charge based on one of the following methods: •   The weight of the good as compared to the total weight of all the goods •   The consideration for the good as compared to the total consideration for all the goods •   The volume of the good as compared to the total volume of all the goods •   Any other method that is reasonable in the particular circumstances. ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2004/08/03 — RITS 52336 — Place of Supply of Goods Supplied by Way of Sale ...

11 September 1998 GST/HST Interpretation HQR0001263- Your File: Lease or Licence Unedited CRA Tags GST/HST Policy Statement P-062, Distinction Between Lease, Licence and Similar Arrangement                                                                         GST/HST Rulings and Interpretations                                                                                                 Directorate                                                                                                 Place Vanier, Tower C, 10th Floor XXXXX                                                                                 McArthur Road XXXXX                                                                                 Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0001263 File 11895-1, 11950-1 Attention: XXXXX September 11, 1998 Subject: GST/HST INTERPRETATION Your File XXXXX: Lease or Licence Dear XXXXX Thank you for your letter of July 22, 1998 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to a contract to operate food concessions at various municipally owned venues. ... Yours truly, Michael Ezri A/Rulings Officer Real Property Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate ...

. / 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 understand that [...], as a broker, clears personal goods as well as commercial goods on behalf of clients. ... Yours truly, Carolle Mercier Unité des questions frontalières / Border Issues Unit; Division des opérations générales et des questions frontalières / General Operations & Border Issues Division; Direction de l'accise et des décisions de la TPS/TVH / Excise and GST/HST Rulings Directorate UNCLASSIFIED ...

1996 GST/HST Interpretation 11715-1[2]- Clarification as to Certain Parts of a GST Application Ruling Issued by the Department on Behalf of                                                                         TELEPHONE 954-8585                                                                         FACSIMILE 990-1233                                                                         11715-1, 11720-1(sn) XXXXX January 1996 Dear Mr. ... At paragraph 13 of the Application Ruling it is stated that XXXXX "... retains for itself a smaller percentage... ... Jones Director General Applications Division GST Rulings & Interpretations          2637(GEN) Mitch Bloom (signoff) c.c.: Application Team ...

We understand that […] [the corporation] is a corporation doing business as […][Merchant] at [#] separate retail locations in [Province 1] […] The Merchant is registered for the GST/HST under Business Number […]. ... Under the terms of the Agreement, the Merchant: * will not submit debit transactions to any other person other than to the Supplier and its designated Vendor; * will connect its POS Terminal only to that Vendor; * will use the POS Terminal for processing all debit and credit card transactions; and * will adhere to all Interac rules, regulations, policies and directives. ... The fees charged by the ISO to the Merchant include a […]¢ Debit Transaction Fee and a […]¢ Communication Fee per attempted or completed credit or debit transaction. ...

Ruling Requested You are requesting that supplies of the following medical products made by XXXXX fall within section 25 of Part II of Schedule VI and thus are zero-rated supplies: •   Fabrics and patches; •   Peripheral grafts and abdominal/thoracic grafts; •   Detachable coils; and •   Embolic agents. Ruling Given The supplies of the following medical products made by XXXXX fall within section 25 of Part II of Schedule VI: •   Fabrics and patches; •   Peripheral grafts and abdominal/thoracic grafts; and •   Detachable coils. ... Yours truly, Susan Eastman Municipalities and Healthcare Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2006/12/05 — RITS 85222 — Delivery- Agent of the Vendor ...

Labelling •   Labelled as a supplement •   Claims that the product has a therapeutic or preventative effect, enhances mental or physical performance, enhances physique, or promotes weight loss. •   Emphasizes a particular nutrient or ingredient found in the product either through the products name or otherwise identified on the label. •   Restrictions on consumption or warnings to who should not consume the product. Packaging & Format •   Packaged in pill, tablet or capsules. •   Packed in formats not usually associated with foodstuffs (e.g. eye droppers). •   The same product is presented in several different formats (i.e., pill, powder, or liquid). ... Smith Goods Unit General Operations and Border Issues Division Excise & GST/HST Rulings Directorate ...

GST Memorandum 700-5-1 " ITC Allocation for Financial Institutions " and CCRA Policy Number P-063 " Output Based Method for Input Tax Credit Allocation " provide guidance on apportioning ITCs. ...