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These amounts include: (a) Check-off fee XXXXX — A check-off fee is imposed on every XXXXX XXXXX sold XXXXX. ... (c) Freight — The producer is responsible for transporting its XXXXX to the XXXXX Auctioneer's stockyard. ... Finally, the CCRA's position is that the supplier, if a GST registrant, is required to collect the GST on the following: •   the check-off fee XXXXX; and •   the buyer's commission. ...

Section […] of the Agreement provides that the Trustee may make payments from the Funds as instructed by certain authorized parties, which, […], includes the Company and any other party authorized by the Company (such as investment managers). Section […] of the Agreement gives the Trustee general powers and duties to enable it to administer the Fund and carry out its responsibilities. ... For example, in the present case, the terms of the Agreement would need to be read in tandem with the plan documents pertaining to the participating plans as well as any other pertinent documents such as the statement of investment policies and […] mentioned in section […] of the Agreement. ...

The following information was presented in your letter. •   ParentCo, a corporation incorporated in the United States, is a non-resident of Canada. •   USCo, a wholly owned subsidiary of ParentCo, is incorporated in the United States and has no presence (place of business, employees, sales representatives, bank account, telephone directory listing, etc.) in Canada. •   CanCo, also a wholly owned subsidiary of ParentCo, is incorporated in Canada and carries on business in Canada. •   USCo contracts, in the United States, to provide "call centre" assistance services to customers in the United States and Canada. •   USCo invoices customers for services rendered. •   USCo has subcontracted with CanCo to provide some of these assistance services through a CanCo facility in Canada. •   Telephone calls from customers in the United States may be routed through USCo to CanCo. •   USCo pays CanCo on an arm's length "cost plus" basis for the subcontracted services. •   CanCo is not acting as an agent of USCo. ... The principal in this case will be more interested in the results of the agent's work and rely on the special knowledge, skill or strength of the agent); •   Whether the entrepreneurial risk must be borne by the agent or the principal; •   Whether the agent sells goods in its own name rather than in the name of the principal; and •   Whether the agent acts as an agent for other persons. ... Leyton Encl.: GST/HST Memorandum 1.4 P-182R P-208R 2004/10/21 — RITS 38435 — Drop-Shipment Rules: Storage Fees ...

For your information, I am enclosing a copy of GST/HST Memoranda Series 1.4, entitled " Goods and Services Tax Rulings ". ... These will then be set onto press where the print size and colour are chosen, according to XXXXX specifications. — Throughout the printing process, XXXXX is required to carry liability insurance in respect of XXXXX information (i.e., intellectual property) contained on its XXXXX, in case of accidental destruction. — Once the brochures or catalogues are printed, XXXXX returns the XXXXX to XXXXX unless the agreement between XXXXX provides that such XXXXX is to be destroyed by XXXXX, following the supply of the printing services. — XXXXX has not been charging the GST/HST to XXXXX. ... For example: — XXXXX must cause physical possession of the brochures to be transferred at a place in Canada to XXXXX. — After physical possession of the brochures is transferred to XXXXX, the latter exports the brochures. — The brochures are not acquired by XXXXX for consumption, use or supply in Canada at any time after physical possession of the brochures is transferred to XXXXX. — After physical possession of the brochures is transferred to XXXXX, and before the brochures are exported, these are not further processed, transformed or altered in Canada. — XXXXX maintains evidence satisfactory to the Minister of the exportation of the brochures by XXXXX. ...

Under a Distribution and Administration Agreement dated February 23, 1994, between the Trust, the Funds, XXXXX and XXXXX the Trust agrees to perform the following: •   arrange for the distribution of redemption fee securities (the "securities") solely through registered dealers and brokers approved by the Funds; redemption fee securities are securities of a fund which may be acquired without payment of a sales charge at the time of purchase but in respect of which a deferred redemption fee may be payable if they are redeemed before a specified time period; •   pay the selling commission in respect of redemption fee securities which are issued and for which full payment is received; XXXXX of the fee is to be paid to the registered dealers and brokers and XXXXX of the fee is to be paid to XXXXX for payment of its sales and promotional expenses; •   provide or cause to be provided the following administrative services: •   establish and maintain a register to record the names and addresses of the holders of the securities; •   establish practice and procedures for and approval of the transfers of the securities and register such transfers; •   approve the form of certificates representing the securities from time to time; •   establish practices and procedures relating to the issuance of certificates representing the securities, arrange for the issuance of certificates and issue replacement certificates when necessary; •   prescribe the form, manner and minimum amount for the subscription of the securities; •   accept or reject subscriptions for the securities in whole or in part in its discretion and, upon acceptance of a subscription, issue to the subscriber the securities and, upon rejection of a subscription, make a prompt refund to the subscriber; •   prescribe the form and manner of redemption requests requiring a Fund to redeem all or any part of the securities held by a security holder; •   accept and process redemption requests from security holders; •   accept notices in writing from holder of the securities who assert their right to receive distributions of income and capital gains in cash; •   credit, pay and otherwise process the distribution of income and capital gains to holders of the securities on the record date for such distributions; •   annually distribute to security holders such information which may be required by securities regulation and policy and such information regarding the Funds which the Trust and XXXXX consider desirable. 4. ... The Trust is compensated as follows: •   in the case of each trustee fund XXXXX, an annual rate of XXXXX % of the net asset value of the securities; •   in the case of XXXXX and the XXXXX XXXXX an annual rate of XXXXX % XXXXX respectively of the net asset value of the securities; •   in the case of all funds, all the deferred redemption fees payable on redemption of the securities of such fund. 6. For the purposes of calculating the GST payable for the services provided, the parties have agreed that a reasonable allocation of the above fees is XXXXX % for the administrative services provided and XXXXX % for the distribution services provided. ...

These systems include some custom designed and developed software by XXXXX and some hardware. •   XXXXX[.] ... Interpretation Requested •   Is XXXXX required to register for purposes of the GST/HST? ... Also enclosed for your client's information are the following Departmental publications: •   Technical Information Bulletin B-037R dated November 1, 1994 entitled "Imported Computer Software", •   Policy Statement P-107 entitled "Certificate for Pre-retail Drop-Shipments", and •   Doing Business in Canada- GST/HST Information for Non-Residents. ...

XXXXX and XXXXX, each own XXXXX % of XXXXX, a commercial building located in XXXXX. 2. ... XXXXX has charged and remitted GST on consideration attributable to XXXXX % of the space that XXXXX occupies in the building (i.e., XXXXX %, which is XXXXX ownership interest in the space occupied by XXXXX). 5. ... You have asked us to confirm that no GST is payable with respect to the portion of the premises owned and occupied by XXXXX (XXXXX % of the XXXXX %). ...

25 July 2002 GST/HST Interpretation 41448- Staff Retreat Held Off Reserve By A Band Or Band-empowered Entity Unedited CRA Tags GST/HST Technical Information Bulletin B-039R, GST Administrative Policy — Application of GST to Indians Kevin Pratt Manager, XXXXXDave Caron Manager, Aboriginal Affairs Unit PSBs and Government Division Excise & GST/HST Rulings Directorate July 25, 200241448 Subject: Staff Retreat Held Off Reserve By A Band Or Band-empowered Entity This is further to your e-mail of XXXXX, in which you requested our comments regarding the subject matter. Under Technical Information Bulletin B-039R " GST Administrative Policy- Application of GST to Indians " (TIB-039R), Indian bands and band-empowered entities are required to pay GST/HST on their off-reserve purchases of transportation, short-term accommodation, meals and entertainment. ... In our view, a staff retreat will qualify as a band management activity provided: •   it is sponsored by an "Indian band" or "band-empowered entity", as defined in TIB-039R; •   it is for consumption or enjoyment of staff members (i.e., band officials) of the band or band-empowered entity; •   staff members attend the staff retreat in an official capacity; •   it is open to all staff members (or is open to all staff members of an identifiable group, such as a unit, should the band or band-empowered entity have a large number of staff members) and is not restricted to selected staff members; •   it is not simply a non-work related social event; •   it is held at a business location; •   the supplies in respect of the staff retreat are purchased by the band or band-empowered entity; •   the expenses incurred by the band or band-empowered entity for each staff member in respect of the staff retreat are reasonable in the circumstances. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... EXPLICATIONS (1) Le remorquage du véhicule à moteur du site de l'accident à un garage se passe non seulement avant le transfert de propriété du véhicule à moteur, mais avant la déclaration de " perte totale " de l'évaluateur d'assurances qui rend son évaluation au garage dans la plupart des cas. ... Veuillez agréer XXXXX l'expression de nos sentiments distingués Bao Tran Unité des Taxes spéciales Division des Institutions financières et Immeubles Direction de l'accise et des décisions de la TPS/TVH 2005/05/12 — RITS 49850 — Application of the GST/HST to the Activities of the XXXXX ...

The following facts were provided in your submission: •   XXXXX signed an employment agreement with XXXXX (Club) for a period of two years ending September 14, 1995. This agreement was used for discussion purposes to renogotiate the agreement for the next two years, which ended September 18, 1997. •   XXXXX scouted the United States (US) teams which included high schools, junior league, college league and US teams in the Canadian major junior league. •   XXXXX also scouted x National Hockey League (NHL) teams consisting of five Canadian teams and 21 US teams. •   Teams in Europe, Sweden, Finland, Czechoslovakia and Russia were also scouted by XXXXX[.] •   XXXXX attended training camp for the Club in XXXXX annually. •   XXXXX tracks statistics on the players at all levels and maintains these records using equipment from his office in his home. •   XXXXX is entitled to bonuses based on the play off performance of the Club. ... If he does not fulfill the conditions of his contract, then the contract will not be renewed by the Club. •   XXXXX is eligible for pension benefits, if any, which are customarily made available to employees of the Club. •   XXXXX provides his professional expertise as a hockey scout and sets his own scouting schedule under the general supervision of the Club. ...