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. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... These fees are payable to the Association by XXXXX. •   Each Provincial Body shall appoint to the Board of Directors one representative for every XXXXX or portion thereof, to a maximum of XXXXX and each representative present at a meeting shall have the right to exercise one vote. •   The President of each Provincial Body shall be entitled to attend the Association's annual general meeting. •   The Association publishes XXXXX. ... Gaudet Charities, Non-profit organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2005/07/29 — RITS 59279 — Application of the GST to the Construction of a New Home ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... XXXXX pays the XXXXX refund to the Lessee. •   A sample XXXXX contract has been provided. •   When a customer enters into a lease or purchase agreement for a vehicle, the dealer may accept a trade-in vehicle as partial payment toward the new acquisition. •   An individual may have a passenger vehicle registered only in the individual's name that is used only for personal use and that the individual wishes to trade in. ... Yours truly, Ben Boboski Goods Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2007/04/19 — RITS 84251 — Independent Medical Examinations and Related Services ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The Occupancy Agreement provides that the agreement is terminated: •   Following the election by the Resident to vacate the premises; •   Upon the death of the Resident; •   Following the election by XXXXX, in accordance with the terms of the agreement, to terminate the Resident's residency. 5. ... Yours truly, Béatrice Mulinda Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate Legislative References: Paragraph 6(a) of Part I of Schedule V Subsection 182(1) Ref: XXXXX P-215, P-225 NCS Subject Code(s): R-11830-11, 11950-1 2004/08/26 F — RITS 49943 — Traitement fiscal des frais de transfert et de sortie payés aux assureurs ...

Company A has no permanent establishment or employees in Canada. •   Company A purchases Product X in Canada from a GST/HST registered resident, Company C. •   Company C transfers physical possession of Product X (at a place in Canada) to Company B, a GST/HST registered resident corporation, who will process Product X. •   Company A retains ownership of Product X at all times. •   Company B processes Product X by adding other materials to create Product Y, which is exported from Canada by Company A. •   Upon receiving physical possession of Product X, Company B issues a drop-shipment to Company A's supplier, Company C, indicating that Company B has assumed liability to pay or remit any amount of tax that may become payable. As a result, Company A does not pay the GST on the acquisition of Product X. •   In addition, as Product Y is exported, Company B does not charge Company A the GST for its services in respect of processing Product Y. •   In certain circumstances, Company B imports Product X into Canada. ... These customers are GST/HST registrants who are acquiring By-product Z for use in their commercial activities. •   Company B intends to acquire drop-shipment certificates from Company A's GST/HST registered customers so that Company B will not Charge Company A the GST in respect of By-product Z. •   As an unregistered non-resident, Company A will not charge its customers the GST or the HST on the sale of By-product Z. •   Products X and Y and By-product Z are all taxable products (i.e., either subject to the GST or the HST). ...

Factors indicating a supply is that of a service of instruction in a course include: •   the activity involves the provision of systematic instruction; •   the supplier monitors or supervises the progress or learning of the participant; •   the supplier assesses the participant's progress during the course of the activity and provides ongoing support, feedback and guidance to the participant; •   the supplier may be available to assist the participant with the subject matter at a time and location different from the time and place in which the activity occurs; •   the supplier assesses the competency of the participant upon completion of the activity by requiring the participant to formally demonstrate the knowledge the participant has acquired and if the competency is not achieved, the activity may have to be repeated; •   the participant is required to invest time and effort outside of the activity (e.g., completing assignments, reading course material); •   successful completion of verified prerequisites may be required before the participant may take part in the activity; •   the participant may be required to successfully complete the activity before being permitted to participate in another activity; •   the activity is part of a series of activities leading to a formal recognition of skills; •   the activity may be part of a program that consists of a series of two or more related activities; •   the activity occurs at set intervals over an extended period of time such as weeks or months; •   the activity does not include the provision of rights or if there is a provision of rights they are incidental to or part of a single supply of a service; •   the subject of the activity is broad; •   the supplier advertises or promotes the activity as instructing participants; •   the activity is promoted together with other activities in a prospectus or calendar prepared by an educational institution; •   the promotional material indicates that the activity is part of a broader program which may lead to a formal recognition of skills; •   the promotional material is aimed at persons who possess any prerequisites required to participate in the activity. Factors indicating a supply is that of an admission to a workshop or seminar include: •   there is little individualized interaction between the supplier and the participant; •   attendance at the activity is sufficient for the participant to receive evidence of successful or satisfactory completion of the activity; •   the supplier's purpose with respect to the activity is principally to provide information to, or to facilitate the exchange of information amongst, participants; •   the subject of the activity is narrowly focused; •   each activity is discrete with no formal prerequisites for attendance; •   participation in the activity does not serve as a prerequisite for participation in another activity; •   the activity is promoted as a stand-alone activity; •   the activity is promoted as a workshop or seminar to the general public; •   the activity occurs during a brief, concentrated period of time, such as a few hours, a day or a few consecutive days. ... Yours truly, Nadine Kennedy, CMA Charities, Non-profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2007/07/26 — RITS 63048 — Application of GST/HST to Fully-serviced Mortgages ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... Our understanding of the facts is as follows: [...] (the "Company") is registered for GST/HST with Business Number [...]. ... The invoices dated for [yyyy] and early [yyyy] are forwarded to the trustee [...] for payment from the pension fund. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... We understand as follows: 1) […] ([…][FinanceCo]) is proposing to offer a new financing product for the Islamic community which is compliant with Sharia Law. ... The amount to be paid in each term will include the portion of [FinanceCo’s] Contribution to be purchased in that term plus the Profit established for that term. h) Subsection […] provides that, at the end of the […] term, the Purchaser may pay the entire remaining balance to repurchase [FinanceCo’s] Contribution, which would terminate the Agreement. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... XXXXX Interpretation Given Passenger Transportation Service and Continuous Journey (Question 4): A passenger transportation service is any mode of transportation available to the public, such as transportation by bus, taxi, train, aircraft, or boat, as long as there is: • a mode of conveyance; • an operator of the conveyance independent of the traveller; and • an itinerary. ... When more than one passenger transportation service is provided and separate tickets or vouchers are issued for the different legs of the journey of the individual, all of the legs may be part of one continuous journey if all of the following conditions are met: • all of the tickets or vouchers are issued by a single supplier, or from an agent acting on behalf of all the suppliers; • all of the tickets or vouchers are for the same individual; • there is no stopover between any legs of the journey for which separate tickets or vouchers are issued; and • the supplier or agent can show CRA that it has met all the above conditions. ...

One shipment of [#] books was imported from […][Country X] at no cost and another shipment of [#] books was imported from […][Country Y] at a reduced cost. 2. ... Therefore, we must look to dictionary definitions of the terms. * Consignment means placing any material in the possession of another person, but retaining ownership until the goods are sold by the other person. * Approval means a good being subject to examination by a potential purchaser without the obligation to buy it after which title passes. * Sale-or-return means an arrangement by which a recipient pays only for goods sold, returning those that are unsold to the wholesaler or manufacturer. ... The provisions provide for a rebate for the following reasons: * damage, deterioration or destruction from the time of shipment to Canada to the time of release, or a loss in volume or weight arising from natural causes while in a bonded warehouse (section 73); * damaged, deteriorated, or destroyed, or quantity are less than the amount for which duty was paid, or the quality of the goods is inferior (section 74); and * defective goods (section 76). ...

Included in your inquiry was a submission from [the Company]s representative, […]. ... He further submits that even if the [driving] services are not freight transportation services, the […] [towing] services […] should be considered to be freight transportation services. ... Based on [the CRA's] position, which is supported by the TCC in Andrews, […] [towing] services, would also not be considered freight transportation services if […][the vehicles] were not being transported […] by a vehicle owned by [the Company]. ...