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Facts •   The XXXXX is comprised of magazine publishers, subscription sales agents and fulfilment houses. ... Policy statement P-182, " Determining the meaning of Agent and Agency ", details the guidelines for use in determining whether or not an agency relationship exists for purposes of the GST/HST. ... As discussed, this treatment of domestic sales of publications is consistent with the treatment of imported publications as detailed in Policy P-185R, " Imported Prescribed Publications and Subscription Agents "[.] ...

For this service, the Company will receive a fee from the non-resident individuals. •   Agreements before September 25, 2006: The XXXXX: •   You have provided a copy of a XXXXX Agreement between the XXXXX Hotel XXXXX and the Sponsor that was entered into on XXXXX. •   The XXXXX agreed to hold a block of approximately XXXXX guestroom nights for use by attendees of the Convention and their guests. ... Ruling Given Based on the facts set out above, we rule that the non-resident attendees and their guests who stayed at: •   the XXXXX and were identified under group folio designation XXXXX, •   the XXXXX and were identified under the group folio designation of XXXXX, •   the XXXXX and were identified under the group folio designation of XXXXX, •   the XXXXX and received the Convention group rate, are eligible for a rebate of GST paid on short-term accommodation, provided that they meet all of the requirements. ... As indicated on the CRA's web site at http://www.cra-arc.gc.ca/tax/nonresidents/visitors/becoming-e.html, the following mandatory information must be clearly stated on your Power of Attorney: •   that you are a private company and are not affiliated with the Government of Canada or the CRA; •   complete upfront disclosure of your fee structure (i.e. the cost to the claimant for using your services); •   that it is for a refund of the GST; •   the client's first name and last name, address, telephone number, email address (if applicable) and signature; and •   the client service mailing address, telephone and fax numbers, and email address of your Company. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... To illustrate, a financial institution may provide an actual amount on line 060 and provide an estimated amount on line 061. line 060 = XXXXX and is not an estimated amount line 061 = XXXXX and is an estimated amount line 062 = XXXXX(Total of line 060 and 061) In this example a financial institution would not be able to report on line 062 an amount other than XXXXX even if that amount includes an estimated amount on line 061. ... Yours truly, Ivan Bastasic Director Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2008/02/14 — RITS 100388 — XXXXX Shake XXXXX ...

Laflèche Files: 11585-17                                                                         11783-2/ss. 123(1) XXXXX February 1996 Subject: Lease assignment from XXXXX This is in reply to the memorandum from XXXXX of your office wherein he requested an opinion concerning a lease assignment agreement between the above-noted parties. ... They further agree that the Assignee shall have no recourse against the Assignor for the obligation of any lessee. •   If the lessee fails to pay rent under a lease, the Assignor shall continue to remit to the Assignee for 30 days after the default, the amount equal to the unpaid rent due, unless it obtains the Assignee's written consent. •   The Assignee may elect not to have the Assignor act on its behalf or can rescind its authorization given to the Assignor to do so. ... The Assignee shall have no recourse against the Assignor for the obligations of any lessee under any lease. •   The Assignee agrees to reassign any lease with the equipment and other property related to the Assignor a) if the lessee wishes to upgrade the equipment or the lessee is in default and the Assignor wishes to repurchase the lease package, or b) at the Assignor's option for $ 1.00, when the lessee exercises the purchase option or when the lease expires. •   The Assignee can't sell or assign its interest in the lease package outside of a reassignment to the Assignor and an assignment to an affiliate of the Assignee. ...

1 March 1996 GST/HST Interpretation 11783-2[2]- Assignment of Lease Payments From Unedited CRA Tags ETA 123(1) business                                                                         11783-2/ss. 123(1) XXXXX March 1996 Subject: Assignment of lease payments from XXXXX Mr. ... Our understanding of the facts of the XXXXX assignment agreement is as follows: •   The agreement between XXXXX provides that the Assignor sells, assigns and transfers to the Assignee all of its right, title and interest in and to each lease, the equipment under each lease, all rent and other sums payable or receivable pursuant to the terms of each lease and all property derived directly or indirectly from any dealing with any lease, the equipment or proceeds. •   The agreement provides that the Assignor is appointed by the Assignee to manage and administer each lease as agent of the Assignee. •   The agreement further provides that the Assignee does not assume any obligations under any lease or in respect of any equipment and that the Assignor agrees to honor such obligations as are binding on it under each lease. •   The Assignor shall indemnify the Assignee against all claims, demands, losses "... which the Assignee may suffer or incur arising out of or in connection with breaches of the Assignor's obligations...". •   Where a lessee defaults under the terms of its lease, the Assignee's remedies shall be against such lease, and the rent, the proceeds, the equipment and the lessee thereunder, and the Assignee shall have no recourse against the Assignor with respect thereto. •   The Assignee may (where the Assignor fails to pay promptly or breaches any covenant) by notice relieve the Assignor of all of its responsibilities whereupon the Assignor's rights and obligations will cease and the Assignor will immediately notify each lessee of the assignment of its lease and direct each lessee to remit all due and future rent to the Assignee. •   The Assignee also agrees that any lease will be reassigned to the Assignor in accordance with the terms and conditions of the agreement, in circumstances where the lessee wishes to upgrade the equipment, or after the expiration of the term of the lease. •   The Assignee also agrees that it will not sell or assign its interest in the lease without giving notice to the Assignor of any offer and obtaining the Assignor's consent. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... This information must include: • details of the supplier (hotel name, address, telephone number, GST/HST registration number); • details of the recipient (company name, address, telephone number); • details of the supply (description of accommodation, number of nights, price); • the GST/HST charged; and • proof that the amount was paid (e.g., copy of cancelled cheque, wire payment confirmation number). ... The form GST115 indicates that if asked by the CRA, a non-resident non-registered tour operator will also have to provide the following information from its books and records: • a list of names and addresses of the non-residents who purchased the eligible tour packages; • the name(s) of the agent(s) through whom they sold the eligible tour packages (if applicable); • copies of invoices issued to non-residents who purchased the eligible tour packages; and • a list of the names and addresses of the non-resident individuals to whom the short-term and/or camping accommodation was made available. ...

16 October 1998 GST/HST Interpretation HQR0001369- New Housing Rebate for Individual Builder Unedited CRA Tags ETA 256                                                                         GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX XXXXX Case: HQR0001369 NCS 11950-01 Attention: XXXXX October 16, 1998 Subject: GST/HST INTERPRETATION Re: New Housing Rebate for Individual Builder Dear Sir: Thank you for your facsimile of October 8, 1998 concerning the application of the Goods and Services Tax (GST) insofar as an entitlement to a GST/HST New Housing Rebate based upon the scenario provided below. ... Statement of Facts Based upon the information provided it is our understanding that: •   an individual acquires land, •   constructs a single unit residential complex (complex) thereon in the course of the individual's business, •   claims input tax credits for GST paid of $4,200 on the taxable costs totaling $60,000 related to the acquisition of the land and construction of the complex, •   occupies the complex as a primary place of residence following substantial completion of the complex, and •   remits the GST payable arising from the self-supply of the complex. ... Since in this case the fair market value of the completed complex is $100,000 and the GST paid arising from self-supply of the complex is $7,000, the GST/HST New Housing rebate is calculated as in accordance with subsection 256(2) of the ETA follows: Where the fair market value of the substantially completed complex is less than $350,000, the lesser of: •   $8,750, and •   36% of $7,000 (being the total tax paid). ...

24 February 1998 GST/HST Interpretation HQR0001006- Schedule VI, Part V, Section 21 to the Excise Tax Act Unedited CRA Tags ETA Sch VI, Part V, 21                                                                         GST/HST Rulings and Interpretations Place Vanier, Tower C, 9th Floor 25 McArthur Avenue Vanier, Ontario K1A 0L5 XXXXX File: 3(glr) XXXXX                 Case: HQR0001006 XXXXX                 Sch. ... The following information was provided in your letter: •   Your client provides a semiconductor analysis service to customers located both in and outside Canada. •   The customers will place orders with your client to purchase certain semiconductor chips (chips) with the intent of having the chips analyzed to determine the chips' functionality. •   Your client will purchase the chips and conduct the analysis. •   Your client examines the chips and maps them to determine the chips' capabilities.. •   In order to map the chips, close attention to detail must be taken as mistakes in the technical diagrams may provide an inaccurate determination of the chips' functionality. •   The analysis process generally results in the destruction of the chips. ... Ryhorchuk Legislative References: Schedule VI, Part V, section 21 to the Act Department of Finance Explanatory Notes dated February 1993                                                 Roget's II The New Thesaurus Policy Statement P151 NCS Subject Code: 3 ...

9 May 1995 GST/HST Interpretation 11745-4- FST Inventory Rebate Unedited CRA Tags ETA 120                                                                         Telephone: (613) 954-8585 Fax: (613) 990-1233 File: 11745-4(kpm) s. 120  XXXXX Attention: XXXXX District Chief, Interpretation & Service, Excise/GST May 9, 1995 I refer to your telephone discussion with Garry Ryhorchuk of my staff on February 3, 1995, regarding the eligibility for the federal sales tax (FST) inventory rebate provided by section 120 of the Excise Tax Act (Act). ... The difference between the $ XXXXX shown in the accounting records and the $ XXXXX covered by the claim represented ineligible items such as lands and building. ... Assuming the position that there was a partnership agreement in place on January 1, 1991 — which would indicate that there were errors in the audited 1990 statements — it is doubtful that the particular assets were sold "in the ordinary course of a commercial activity. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Registrants are also required to file the Form GST106, Schedule 2 – Information on Claims Paid or Credited for Foreign Conventions and Tour Packages in respect of any eligible tour package that is sold for which: •   the GST/HST charged on the eligible tour package becomes payable after March 2007; and •   the registrant claimed a deduction in its net tax for an amount paid or credited to a non-resident after March 2007. ... Yours truly, XXXXX Services and Intangibles Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2007/10/19 — RITS 93865 — Foreign Convention and Tour Incentive Program ...