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Facts in Common for Fact Pattern Numbers 1, 2 & 3 •   X Co. is a U.S. company. ... CanCo is registered for GST/HST purposes, and is engaged exclusively in making taxable supplies. •   The employees and directors of CanCo to which the maintenance and support services may be rendered are residents of Canada. •   Y Co. is a Canadian resident company that is registered for GST/HST purposes. •   X Co. contracts with Y Co. to undertake the maintenance and support services on its behalf. ... Fact Pattern Number 3 •   Same as Fact Pattern Number 2 except that the support services include on-site assistance. ...

Most of the additional information centered on the activities on the permanent establishment of the general partner in the U.S. and the structure of the partnership: •   The permanent establishment consists of an office in XXXXX and several employees who handle the day-to-day activities of the general partner. •   The telephone number and mailing address of the general partner are at this fixed place of business. There is also a long-term lease in effect for this particular office. •   The general partner pays U.S. corporate income tax as a resident corporation. •   The limited partnership pays U.S. taxes as a resident partnership and is subject to U.S. regulations concerning limited partnerships. •   The limited partnership offers its partnership units in Canada, and is therefore subject to XXXXX •   Notwithstanding the fact that the general partner is incorporated in XXXXX the general partner does not maintain any type of presence in Canada. •   All business decisions respecting the limited partnership is made through the office in XXXXX •   All contracts and other business agreements respecting the limited partnership and the corporate general partner are made through the office in XXXXX •   The general partner maintains bank accounts in the U.S. through the office in XXXXX •   The books and records, while kept in Canada (because they are done by a third party), follow U.S. accounting rules. •   The management services indicated in Annex A of the original letter are not done by the general partner, but rather, subcontracted out to a third party. •   The general partner is solely responsible for all management services. •   The management services are supplied to the general partner (any contractual arrangements entered into are entered into by the general partner and the third party). ... It asks us to consider the following factors: •   Are the items listed in Annex A inputs or supplies in their own right? ...

[…]. […] according to the […][documentation] you provided, the policy is issued by the insurer to the owner (defined as the person who owns the new home), to provide insurance to the owner and not to the builder. […]. ... As indicated in that policy, new home warranty insurance provides coverage for certain defects in the residential complex. […]. […]. ... According to the builder agreement […], the builder agrees to […] and pay […][the] fee to the insurer at the onset of construction to enroll a particular home in a new home warranty program. ...

We understand from your letter, our telephone conversations and the information found on the Association's website that: •   The Association is a non-profit provincial sport-governing body that oversees community-based minor hockey programs throughout a designated geographic region XXXXX. •   The Association is a non-profit organization, as that term is defined in subsection 123(1) of the Excise Tax Act (the ETA). •   The minor hockey associations (the Locals) in the designated region are members of the Association. •   The Association is a member of the XXXXX (the Branch), which is in turn a member of the XXXXX (the National Association). •   The Locals provide a wide array of hockey opportunities for residents of the cities, towns, villages and municipalities they serve. •   The right of a player to play for his/her Local is protected through the regulations of the National Association, the Branch and the Association. •   As indicated in its constitution, the Association's first objective is to promote, encourage, govern, organize, co-ordinate and develop minor hockey programs for all ages up to and including the Juvenile age division for players in the Association's designated region. •   According to the Association's Mission Statement, the Locals provide a wide array of hockey opportunities for minor players at all skill levels. Most Locals provide a representative team program, a local or house league program and, when possible, select team programs for players. •   Skills development programs, including the XXXXX are major facets of player skills development initiatives within the Association. •   In order to fulfill its objectives, the Association administers the XXXXX which consists of organized regular season hockey play in local, house or select leagues; play downs that follow the regular season for the same; appeals of suspensions, fines, etc. which occur throughout the season; and sanctioned tournaments for various league and team play. •   The league programs are provided to the players by the Locals. •   The Association provides certification programs for all coaches, trainers and referees. •   The Association has determined that the XXXXX is provided primarily (more than 50%) to children 14 years of age and under. •   Membership includes liability and accident insurance, taken out by the Branch, for the individuals. •   The teams also pay team registration fees, house league fees, play down fees and appeal fees to the Association. ... Section 12 of Part VI of Schedule V to the ETA exempts, in part, supplies made by a public sector body (PSB) of membership in, or services supplied as part of, a program established and operated by the PSB where: •   the program consists of a series of supervised instructional classes or activities involving athletics or other recreational activities; •   it may reasonably be expected, given the nature of the classes or activities or the degree of relevant skill or ability required for participation in them that the program will be provided primarily to children 14 years of age or under, and •   the program does not involve overnight supervision throughout a substantial portion of the program. ...

Sachant qu'il ne se prévaudra pas entièrement de son quota pour ses propres besoins, il prend une entente avec un autre importateur canadien, "B", pour le faire bénéficier de son avantage. •   A et B sont inscrits aux fichiers de la TPS •   À chaque début d'année civile, A confirme par écrit à B qu'il pourra importer au cours de l'année une certaine quantité de marchandises sous le nom de A. •   B commande et paie directement les marchandises à un fournisseur non-résident et non inscrit. Le nom de A ne figure pas sur la facture du fournisseur. •   Lors de l'entrée des marchandises au Canada, la TPS est perçue aux douanes et est acquittée par un courtier en douanes. •   Ce courtier en douanes est le courtier avec qui A fait habituellement affaires. •   La facture des douanes mentionne le nom du fournisseur non-résident, le nom de A et, en tant qu'acheteur, le nom de B. •   En aucun moment A n'a la possession ou la propriété des marchandises, lesquelles sont livrées directement à B. •   Le courtier en douanes demande le remboursement de la TPS qu'il a acquittée et facture ses honoraires de courtage (TPS incluse) à A, soit celui au nom duquel le permis d'importateur a été émis. •   A, à son tour, demande à B de lui rembourser la TPS payée à l'égard de l'importation des marchandises et les frais de courtier en douanes (incluant la taxe) ou encore de payer directement le courtier en douanes. ... Routhier Telephone #:                           (613) 954-8585 Fax #:                                      (613) 990-1233 ...

10 May 1999 GST/HST Interpretation 11872-2- Application of the GST/HST to the Operations of a Band Empowered Entity Unedited CRA Tags Technical Information Bulletin B-039R, GST Administrative Policy — Applications of GST to Indians TO: XXXXX XXXXX XXXXX FROM: Suzanne Leclaire Public Service Bodies and Governments GST/HST Rulings and Interpretations Directorate Subject: XXXXX Thank you for your letter of January 5, 1999, with attachments, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the operations of the XXXXX[.] ... These above noted documents provide that: •   XXXXX is an incorporated body established through a XXXXX XXXXX of the XXXXX that have entered into service delivery agreements. •   the XXXXX[.] •   the XXXXX shall have the full and complete management, control and disposal of the affairs, property and funds of XXXXX has territorial jurisdiction on XXXXX which have initially been approved by the XXXXX to receive child welfare services from XXXXX and which have in effect a resolution of the band agreeing to the provision of child welfare services by the XXXXX[.] •   the objects of XXXXX include: •   to operate in all respects as a XXXXX within the meaning of any and all statutes of the XXXXX and regulations thereunder; •   to plan, develop, deliver, co-ordinate and administer services for children and families including guidance, counseling, support and other services to children and families; •   to do all things necessary for the protection of children; and •   to provide appropriate residential placements for children requiring such placements. ...

The relevant [Act] provisions in this case are sections […]. […][Levy X] Section […] of the [Act] allows a municipality to pass bylaws giving the municipality the right to impose a levy ([…]) on developers […]. ... This servicing agreement pre-dates a subdivision approval or a development permit, but deals with the same improvements […] required […] under a development agreement. ... The […] agreement between a county and a corporation […] allows the corporation to construct vehicular access to its lands from a road under the care and control of the county. […]. ...

Statement of Facts Our understanding of the facts is as follows: •   XXXXX is a registered mutual fund dealer with approximately XXXXX sales associates that solicit applications for the purchase of mutual fund securities, life and disability plans and other securities or financial products. •   XXXXX is the manager and trustee of certain mutual funds. •   XXXXX has retained XXXXX as transfer agent of the mutual funds managed by XXXXX[.] Pursuant to the Broker/Dealer Service Agreement XXXXX (the "Broker") authorizes and directs XXXXX upon receipt of a wire order instructing XXXXX to redeem or purchase any securities of mutual funds managed by XXXXX registered in the name of the Broker and upon receipt of a copy of the Net Settlement Report signed by an authorized officer of the Broker to redeem or purchase any such securities referred to therein without any other documentation or authorization. •   Upon completion of the processing of the redemptions and purchases referred to in the wire order and the Net Settlement Report, where net proceeds of all redemptions less any applicable redemption fees exceed purchases, a cheque for settlement will be forwarded to the Broker. •   If purchases exceed the net proceeds of all redemptions (including applicable redemption fees), a cheque for settlement of the net amount will be forwarded to XXXXX and will be payable to XXXXX[.] •   Net Settlements cannot be used for the redemption of securities registered in the clients name. •   The agreement between XXXXX (the "Broker") and the sales associate (the "Associate") includes: •   The Broker hereby appoints the Associate to solicit applications for the purchase of: Mutual Fund Securities; other Investment Products; Life and Disability Insurance Plans, for which the Broker may now or hereafter act as distributor. •   The Associate shall, in the conduct of his/her business, pay all the costs and expenses arising out of his/her business. ... He indicates that the service consists of: •   XXXXX must review each transaction to ensure that it meets the requirements of XXXXX as well as the stated investment requirement of the investor. •   XXXXX must maintain copies of all sales related paperwork containing investors signature in a prescribed format for each agent. •   Processing sales orders to the mutual fund companies, receiving commissions from the fund companies and disbursing commissions to the agents. ...

23 December 1996 GST/HST Interpretation 11895-5[1]- Clarification on the Application of the Provisions of Section 22 of Part VI of Schedule V to the ETA to Septic Tank Service Operations Unedited CRA Tags ETA 259; ETA Sch V, Part VI, 21; ETA Sch V, Part VI, 22                                                                         HQR0000317 XXXXX                                                                                 File #: 11895-5(on) XXXXX                                                                                 Case No. HQR321 XXXXX                                                                                 Sch V/VI/ 21 & 22 XXXXX Attention: XXXXX December 23, 1996 Dear Madam: In your letter of October 2, 1996, you sought clarification on the application of the provisions of section 22 of Part VI of Schedule V to the Excise Tax Act (the Act) to septic tank service operations. ...

The sites themselves are much larger. •   The tenants of the XXXXX are taxed by the municipality on their tenant owned improvements to the land. ... Shareholders do not hold title to a specific site. •   Pursuant to the unsigned residency agreement and the "Offer to purchase common shares in the capital of XXXXX[.] •   The resident agrees to purchase from XXXXX and XXXXX agrees to sell the shares in the capital of XXXXX[.] •   For the consideration of XXXXX paid by the shareholding member of XXXXX to XXXXX, the shareholder receives an exclusive residency right for himself, his invitees, tenants and lessees to use and occupy a lot (the agreement allows for a space for the allotment of a specific lot number). •   Upon expiry of the original term of the residency agreement, each shareholder may request a renewal for a further period of XXXXX. •   The right to use and occupy the lot is exclusive to the shareholder. ... None of these are 'camp' sites for short term campers because of a ruling by the XXXXX[.] •   There are XXXXX year round sites occupied by tenants. •   Seasonal tenants usually stay for much shorter periods than the complete season which runs approximately from XXXXX[.] •   The seasonal sites have their water systems drained in the winter as the homes would suffer significant damage if the water systems for seasonal units were not shut off. ...