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Other services which are provided as part of the agreement, but which are not specifically spelled out in the contract, include: •   assist in locating an employer sponsor for the client; •   lobby the provincial government, through the local legislative member, on behalf of a group rather than on behalf of one specific client; •   prepare paperwork and gather information on potential immigrants as part of the necessary research required to pre-qualify the person, which is necessary to advise them of their chances for approval; and •   filing the documents after the qualification stage is complete, which may or may not involve a representative of XXXXX travelling to XXXXX to advise the client. ... I would also like to make the following comments regarding the letter: •   According to the information in the GST Mainframe, the legal name of XXXXX is XXXXX is a trade name. Therefore, I believe the letter should be addressed to the legal entity. •   Office copy information (page 8)- The statement is made that "Services provided in XXXXX are outside the scope of GST/HST". ...

. •   A GST/HST registrant offers goods for sale to consumers through a web site. •   The web site is located in Canada. •   The goods are located in Canada in a non-participating province. •   When ordering goods through the Web site, the consumer, at his option, may choose to have the item gift-wrapped for an additional charge of perhaps $1.00 or $2.00. •   When this option is selected, the gift-wrapping is done at a place in Canada, but not in a participating province. •   The item is gift-wrapped at the same facility from which the goods originate. •   The gift-wrapping is supplied by the same supplier who supplies the goods. •   A separate charge is shown on the invoice for the gift-wrapping. •   The gift-wrapped item is subsequently shipped from that place to the consumer's address. ...

•   Corporation X is resident in Canada and a registrant. •   Corporation X is owned 100% by Canadian parent. •   Canadian parent is resident in Canada and a registrant. •   Corporation C is resident in Canada and a registrant. •   Corporation D owns all the voting shares of Corporation C. •   Corporation D's shares are owned by Corporation X, Corporation A and Corporation B. •   None of Corporation X, Corporation A or Corporation B owns 90% or more of the voting stock of Corporation D. •   Neither Corporation A nor Corporation B is resident in Canada and neither is a registrant. •   Canadian parent owns 100% of Corporation A and Corporation B. ...

Background Our interpretation is based on the following information: •   XXXXX is a U.S. company, headquartered in XXXXX, and is registered for the GST/HST XXXXX. •   XXXXX is in the business of designing, manufacturing and selling visual technology, such as monitors and projectors. •   XXXXX has sales representatives located at its Canadian branch XXXXX. •   While the Canadian sales representatives contact customers to solicit sales of the XXXXX products, all orders are concluded at the XXXXX head office in XXXXX. •   The products are considered TPP for GST/HST purposes. •   XXXXX sells its products to XXXXX with the following terms of delivery: i. ... Freight prepaid as the carrier bills XXXXX for the freight charges. •   XXXXX of the Distribution Agreement between XXXXX and XXXXX states that: XXXXX. •   Based on directives from XXXXX, XXXXX ships (via the carrier) the products directly from its warehouse to XXXXX location in Canada. •   XXXXX is the importer of record (i.e., XXXXX clears the products through the Canada Border Service Agency and pays the applicable duties and taxes). ... Moore Legislative References: 142(2)(a) XXXXX XXXXX NCS Subject Code(s): I 11680-1 I 11680-7 2004/07/30 — RITS 53159 — Transfer or Cancellation of a Prepaid Funeral Arrangement ...

Our understanding of the facts is as follows: •   XXXXX provides specialized forms of group insurance coverage for members affiliated with a particular organization such as a bank, a large retailer, or an association (referred to hereafter as the XXXXX group). •   In an XXXXX program there are additional "arranging for" efforts required after the initial group insurance policy is issued by XXXXX to the group policyholder. The group policyholder offers access to specialized insurance coverage at volume rates to its members in order to enhance the value of the membership relationship. •   A group insurance master policy is issued by XXXXX to XXXXX, the group policyholder, who makes the coverage available to its members (certificateholders) under the terms and conditions of the master policy. •   The initial selling activities between a broker, a sponsor and insurance carrier that ultimately results in the issuance of an XXXXX group insurance policy are largely the same for both "regular" and XXXXX group insurance, as generally described in policy statement P-092 ("Arranging For" As It Applies to Group Insurance). •   XXXXX is required by contract with XXXXX to conduct the necessary insurance coverage-placing activities with members and is usually permitted to use a telemarketing agency for this purpose. •   XXXXX is contracted by XXXXX to conduct the necessary insurance coverage-placing activities with the XXXXX group members. •   The marketing process follows a predetermined script jointly prepared by XXXXX and XXXXX and/or XXXXX may approve/monitor this marketing process. •   Members of the XXXXX group are contacted by telephone and are made aware of the availability of the coverage by the telemarketer representative. •   When a potential customer is identified during the telephone call, the details are forwarded to XXXXX, who has the license to provide insurance services. A representative of XXXXX then completes the telephone call arranging for the placement of the insurance. •   The XXXXX representative prepares the prospective certificateholder's insurance application during this process. •   The completed applications are transmitted to XXXXX for final approval, underwriting and issue. •   XXXXX is compensated on a per-hour basis. ...

-à-d. au moins 10 % dans le cas d'un immeuble) des particuliers visés aux divisions (A) à (G) de l'alinéa 4(1)a) du Règlement. Cela contredit le sens de l'expression «la totalité, ou presque»[,] utilisée dans le Règlement, qui a été interprétée comme signifiant 90 % ou plus, ou moins de 10 % aux fins de la Loi. ... McDonald v. the Queen, 98 DTC 2151, la Cour canadienne de l'impôt déclare que dans le contexte des paragraphes 6(1) et 6(2) de la Loi de l'impôt sur le revenu, l'expression «la totalité, ou presque,» ne doit pas nécessairement être interprétée comme signifiant 90 % ou plus, mais peut [XXXXX] 191.1 de la Loi et la décision de la CCI, nous sommes d'avis que «au moins 10 %» signifie 10 % ou plus. ...

As well, I had requested information on the following questions: •   Who do the assets used by the XXXXX belong to XXXXX? •   Who approves the books and records of XXXXX at year-end? •   Is the office of XXXXX on a reserve? ... Yours truly, Karen Bennett Aboriginal Affairs Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2007/03/21 — RITS 81870 — Acquisition of Farmland Held in Joint Tenancy ...

31 August 1998 GST/HST Interpretation HQR0000947- Payment for Loss of Rental Income XXXXX                                                                         Case #: HQR0000947 File: 11585-0, 11585-21 Att: XXXXX August 31, 1998 Re: Payment for Loss of Rental Income This is in reply to your memo of November 19, 1997 concerning the tax status of an amount charged by a car rental company to its customer for loss of rental income when the vehicle under rental was damaged by the customer who had not purchased a loss damage waiver. ... Facts Based on the terms of the car rental agreement provided, our understanding of the relevant facts of the situation is as follows: •   A renter agrees to rent a vehicle from a car rental company for a consideration which is calculated on a flat daily amount plus a specific charge based on distance driven. •   The renter has the choice of accepting a loss damage waiver for an additional charge which would limit the renter's liability for vehicle damage or loss to a pre-determined amount. •   If the renter decides not to purchase the loss damage waiver, the renter will be required to pay "on demand all loss or damage (however caused) to the vehicle while rented under this agreement". ... Phil Tang, Specialty Tax Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate ...

Based on your facsimile transmission, our understanding of the facts is as follows: •   A self-funding non-profit organization (NPO) has approached XXXXX with a fund raising plan. •   XXXXX will print up "gift certificates" with a face value of XXXXX to be used at XXXXX towards the purchase of bedding plants. •   XXXXX will sell the "gift certificates" to the NPO for XXXXX nd not collect GST. •   The NPO will then sell the "gift certificates" for their face value of XXXXX to individuals and not collect GST. •   The individuals who purchase the "gift certificates" from the NPO will then redeem them towards the purchase of bedding plants from XXXXX. •   The NPO gains XXXXX per "gift certificate" towards fundraising. •   The NPO is a small supplier and is not registered You have requested our views as to the GST consequences of these transactions. ...

The following information is as set out in the XXXXX and an undated document entitled XXXXX •   The XXXXX. ... XXXXX[.] •   The head office of the Corporation is off reserve. •   Membership of the Corporation shall be open to 35 XXXXX First Nation XXXXX (we understand that these entities are 'bands' as defined in the Indian Act), as represented by the elected Chief. ... Each director is authorized to exercise one vote. •   The officers of the corporation shall be two co-chairs elected at the annual general meeting of the members. ...