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As noted in Policy Statement P-091R, entitled " Leased Cars and Net-of-GST/HST Insurance Claims ", and in GST Memorandum 700-5-10, entitled " GST Treatment of Insurance Claims ", the "Net-of-GST/HST" method will apply where the lessor is entitled to claim an ITC pursuant to section 169 of the ETA. ... The provisions only refer to the "... property of a person..." and do not refer specifically to the insured, a lessor or a lessee. ...

You operate a […] (Business) based in […][Canada]. 2. […] [the] Business is registered for GST/HST […] with effective date of [mm/dd, yyyy] and Business Number […]. 3. ... The Project is described as […] 14. The following reward packages established by [the Business for the Project] received [funding] from [Y] […]: * […][Description of items included in each package] 15. […][Information on the delivery of Project reward packages to Y]. 16. […]. ... The elements included in each of the [reward] packages established by the Business are described […] on the Platform […]. ...

The following are key concepts with respect to discretionary complimentaries: •   Patrons earn discretionary complimentary Canadian dollars based on XXXXX. •   XXXXX. •   Only notional Canadian dollar amounts are accumulated based on information from the XXXXX information system in the discretionary account. •   Only Canadian dollar amounts reduce the discretionary account. 5. The following are key policies and information related to discretionary complimentaries: •   Complimentary vouchers are issued at the discretion of XXXXX employees. •   Complimentary vouchers must be used within XXXXX days. •   The unused portion will not be refunded (e.g., meal voucher $10, cost of meal $8.50, reduction in discretionary account $10 and a cash refund is not provided to the patron). •   Complimentary vouchers can be issued to a patron for use at a particular XXXXX facility irrespective of which location the patron earned the discretionary dollar amounts. •   Complimentary vouchers are not issued for "free" goods or services. ... Yours truly, Ken Syer Manager Specialty Tax Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2006/03/30 — RITS 62164 — Cemetery Property and/or Services Under a Pre-need Arrangement ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Yours truly, Don Dawson Corporate Reorganizations Unit Financial Institutions & Real Property Division Excise and GST/HST Rulings Directorate 2005/10/20 — RITS 64563 — Small Supplier Threshold ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Yours truly, Patricia Taylor, CMA General Operations Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2006/02/13 — RITS 76852 — Application of GST/HST to a Certain Supply of Fresh Fruit in a Bowl ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Yours truly, XXXXX Goods Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2007/12/10 — RITS 98192 — XXXXX Crackers ...

. / 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. ... Temporary foreign workers are hired by the registrant and arrive at the [farm] […] and are there for approximately 10 weeks (2 to 2.5 months). 4. ... In considering these factors, the following principles must be considered: * no vacation/transient purpose; * indicators of permanency; * appreciable period of time; * intention; and * purpose of stay. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Statement of Facts We understand that: • XXXXX (the Company), a GST/HST registrant located in XXXXX, arranged for you to travel to XXXXX to receive XXXXX. • The Company provided you with an estimate of the costs for the XXXXX and of the costs for yourself and your XXXXX to travel to XXXXX. ... The breakdown of the estimate, XXXXX, is as follows: XXXXX visa x XXXXX $XXXXX Travel insurance x XXXXX XXXXX Transit hotel x XXXXX XXXXX Airfare x XXXXX XXXXX XXXXX hotel (XXXXX night) XXXXX Hospital charges XXXXX XXXXX resort (XXXXX days) XXXXX Sub total $XXXXX Service charge @ XXXXX% XXXXX GST on service charges ($XXXXX @ XXXXX%) XXXXX Total $XXXXX • Also, on the estimate, the Company indicated that copies of the actual invoices would be provided on completion of the XXXXX, and that the prices were approximate. • You paid an advance of $XXXXX to the Company. • On XXXXX, you and your XXXXX traveled to XXXXX where you had XXXXX. • On XXXXX, the Company provided you with a final invoice for the actual costs as follows: XXXXX visa x XXXXX $XXXXX Travel insurance x XXXXX XXXXX Transit hotel x XXXXX XXXXX Airfare x XXXXX XXXXX XXXXX- XXXXX hotel XXXXX XXXXX Hospital charges XXXXX XXXXX XXXXX resort XXXXX XXXXX Postage and courier XXXXX XXXXX Sub total $XXXXX Service charge @ XXXXX% XXXXX $XXXXX GST @ XXXXX% XXXXX XXXXX Total (Paid in full) $XXXXX Advance Paid $XXXXX Balance $XXXXX Refunded (previously) XXXXX Balance due (cheque to follow) $XXXXX • You noted that on the estimate, the GST was applied to the Company's service charge only, whereas on the final invoice, the GST was applied to the total amount invoiced. • The Company gave you copies of the actual invoices for the costs you incurred. ...

. / 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. ... Based on the information provided, we understand that [the Company] is […] with its head office in Nova Scotia and […] in Nova Scotia, New Brunswick and Newfoundland and Labrador. ... A service and real property would generally be regarded as being in relation to each other pursuant to the above guidelines if the purpose of the service is to: • physically count the property; • appraise or value the property; • physically protect or secure the property; or • enhance the value of the property. ...

Our understanding of the facts is as follows: Statement of Facts The City and XXXXX entered into an XXXXX Services Agreement (the "Agreement") dated XXXXX •   Section 2.0 of the Agreement is entitled "Scope of XXXXX Services". ... Report submitted by XXXXX to the City in May, 1997, a copy of which is attached hereto as Appendix A(2). •   Appendix A(1) lists the following: XXXXX XXXXX •   Included under the heading "Summary" of the Feasibility Study and Concept Report (the "Report") is the following: XXXXX has prepared this Feasibility Study to define annual XXXXX and operating cost savings an capital costs associated with a program of XXXXX conservation and building renewal measures. ... Equipment to be provided under this program includes: •   20 new boilers •   4,000 renovated light fixtures •   new centrifugal refrigeration chiller •   The Agreement also indicates that:... the XXXXX has approved the City entering into this Agreement with XXXXX for retrofit work to be performed in the amount of XXXXX based upon the XXXXX XXXXX Feasibility Study. •   The City will pay the contract price based upon the monthly XXXXX savings that it will realize as a result of the work performed by XXXXX[.] ...