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Unedited CRA Tags ETA Sch V, Part IV, 1                                                                         File 11935-2(EB) XXXXX                                                                                 Leg. ...

Some factors that can be considered in determining whether a place is being used as a person's place of residence would include: •   the place in question is the only residence of the person; •   the occupant owns or leases the premises versus occupying the premises under a licence; •   the place is furnished by the occupant; •   there has been a change of address for postal, municipal taxes and other purposes; •   there is a telephone listing for the occupancy at the premises; and •   the individual has taken out insurance in respect of the home and its contents. ... Factors which would suggest that the place is a person's primary place of residence (but not necessarily conclusive on an individual basis in and by itself) would include: •   the intentions of the individual; •   the actual use as evidenced by time or the degree of permanency; •   factors such as employment or schooling which may dictate that the person would be required to live in the premises; •   the address on their personal records designates this address as the primary address; •   reasonableness of the residence constituting a primary place of residence rather than a secondary residence (e.g. a ski chalet, summer home) or a place of business; •   determined to be so for the jurisdiction of the various taxing authorities; •   may exercise privilege of voting; •   any other legal rights and privileges; •   address provided for memberships or associations (e.g. alumni association, professional association); •   evidence of involvement in community organizations (e.g. block parent, parent-teacher) and •   newspaper or magazine subscriptions delivered to this address. ... Subparagraph 7(a)(ii) of that same Part refers to, "... constructing a residential complex... in the course of commercial activity... ...

Ltd.) provides services to a […] vehicle dealership (dealer) to assist the dealer’s customers in obtaining financing for […] vehicle purchases, such as […]. ... Ltd. will provide the following services to the dealer: * Provide each dealer location with a software program for loan credit applications. * Obtain credit information from the dealer’s customer (the customer). ... Ltd.'s personnel. * Complete and submit the loan application to up to [#] lending institutions for processing. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... For GST/HST purposes, a "convention" means a formal meeting or assembly that is not open to the general public, but does not include a meeting or assembly the principal purpose of which is • to provide any type of amusement, entertainment or recreation, • to conduct contests or games of chance, or • to transact the business of the convenor or attendees in the course of a trade show that is open to the general public, or otherwise than in the course of a trade show. ... A rebate claim that includes an amount paid by an employee, who attended a convention as a delegate of the exhibitor and was reimbursed by the exhibitor, would have to include evidence that: • the delegate is an employee of the exhibitor; • the amounts paid by the employee were for supplies used exclusively in connection with a convention; and • the exhibitor has reimbursed the employee for all or part of the amounts paid by the employee including the GST/HST. ...

My understanding of the facts is as follows: •   XXXXX provides property management services to commercial and residential property owners, pursuant to management agreements it has entered into with the various owners. •   XXXXX has provided the Department with its two standard management agreements, one for commercial property and the other for residential property. ... Liability of contract / liability for payment- Does legal liability for payment rest with XXXXX or with a property owner? ... Insurance, mortgage & property tax payments The following comments are limited to those payments authorized pursuant to paragraph 4b of both standard agreements. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'agence. ... The non-resident is not a "consumer". •   Foreign suppliers who are not registered ship parts to the Canadian resident. ... Legislative References: 169(2) 123(1) NCS Subject Code(s): I 11650-1 XXXXX 2004/09/21 — RITS 46269 — GST/HST Treatment of Interchange Fee ...

. / 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 Our understanding of the facts are as follows: •   Your client, XXXXX is not resident in Canada and is not registered for GST/HST purposes. •   XXXXX will temporarily import XXXXX equipment consisting of XXXXX to be tested XXXXX. •   The testing will take place in XXXXX. * The equipment has a total value of approximately $XXXXX and will be shipped into Canada XXXXX and will be returned to XXXXX. •   For purposes of this test, XXXXX. •   The Canada Border Services Agency has determined that the conditions of Item 17 of the Temporary Importation (Excise Levies and Additional Duties) Regulations (i.e., articles to be tested and specialized test equipment permanently attached to or installed on those articles) are met for the temporary importation of the XXXXX equipment. ... Yours truly, Jeff Frobel Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2008/01/31 — RITS 58133 — Transfers of Farmland ...

It is also named as an insured party under the group policies as it too owns property. •   The sample copies of the insurance polices issued by the insurers XXXXX show that the insurers have provided insurance to the persons named in the policies, i.e. XXXXX[.] •   XXXXX has confirmed that it negotiates the policies, pays the premiums and then is subsequently reimbursed by the other insured parties. ... Our Comments: Our review of this case considered the essential qualities and indicators of agency as enunciated in Policy Statement P-182 entitled " Determining the meaning of "Agent" and "Agency" ". ...

Guerra                                                                         Case: HQR0001259 File: 11595-2 Att: XXXXX September 28, 1998 Subject: XXXXX Dear XXXXX Thank you for your memorandum of July 21, 1998 including the July 16, 1998 memorandum from XXXXX to XXXXX TIS Team Leader, and attached documents, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to certain transactions undertaken by XXXXX. ... Our understanding of the facts is as follows: •   Under the terms and requirements of XXXXX when a XXXXX member institution has failed, XXXXX is required to provide deposit insurance to insured depositors, within the limits imposed by XXXXX (generally, to a maximum of XXXXX per insured depositor). •   In settlement of this insurance claim, one of the methods provided to XXXXX under the XXXXX is to make the insured deposit amounts held with the failed institution (the XXXXX") available to insured depositors by means of placing the insurance settlement amount in another member institution, who then sets up new demand deposits in the amounts and names of the insured depositors, as identified by XXXXX[.] •   This method of settlement is accomplished by XXXXX providing the transferee member institution with a computer tape of depositor insurance information, and a cheque in the amount of the XXXXX[.] •   The transferee member institution then actions the information and settlement amount provided by XXXXX to create the new deposit accounts of, and makes them available to, the insured depositors. •   This procedure satisfies XXXXX obligations to provide deposit insurance under the XXXXX[.] •   The first step in this process involves the tendering by XXXXX of the XXXXX to selected XXXXX member institutions. A letter is sent to these selected institutions inviting them to make a formal offer for the placement of the XXXXX XXXXX according to a number of parameters as enumerated in the letter. •   As quoted in the letter, the successful bidder is required to pay a fee to XXXXX "to reflect the benefit to the institution of acquiring these new deposit accounts". •   The successful bidder has, in all cases, agreed to pay, and has paid the fee to XXXXX for the right to receive the XXXXX[.] ...

The Memorandum contains the following relevant terms: •   The Project shall be undertaken and owned by an unincorporated joint venture XXXXX[.] •   XXXXX each shall have a XXXXX undivided ownership interest in the Venture. ... XXXXX[.] •   XXXXX and the Venture shall enter into contract(s) for the purchase by XXXXX from the Venture of the XXXXX. ... Tang Specialty Tax Unit Financial Institutions & Real Property Division GST/HST Rulings & Applications Directorate. c.c.:      XXXXX ...