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As the transactions described in your letter are carried out in [...] ... The Purchaser obtains financing for the purchase of the Property from the [...] ... Under paragraph [...], the Purchaser's requirement under paragraph [...] can be carried out through a series of renewable payment arrangements each for a specified term. ...

We understand that [...] has concerns with the application of the changes to the definition of financial service to investment dealer services. More specifically you have concerns regarding: • investment dealers arranging for the purchase or sale of securities on behalf of a client; • investment dealers arranging for the purchase or redemption of mutual funds on behalf of a client as it relates to trailer fees; and • underwriting fees. ... An asset management service includes a full range of investment portfolio management and administration activities rendered by one person in respect of the assets or liabilities of another person, such as: • managing or administering the assets or liabilities with or without discretionary authority granted by the other person to manage those assets or liabilities. • providing research, analysis, advice or reports in respect of those assets or liabilities; • determining which assets or liabilities are to be acquired or disposed of; and • acting to realize performance targets or other objectives in respect of the assets or liabilities. ...

Policy P-103R, " Transfer of an Undivided Interest in a Joint Venture " (copy attached) outlines when a sale of an undivided interest in a joint venture would meet the above two conditions. The joint venture must be a business that is established or carried on, and has the following characteristics: •   it is a group of persons engaged in a specific business for a limited period; •   the business is not structured as a corporation, a partnership or a trust; •   each participant has a direct undivided interest in the joint venture property and in the commodity produced by the joint venture; •   each participant is a party to all the joint venture agreements such as the operating agreement and the ownership agreement; •   each participant has a right of mutual control and management of the business; and •   the participants make a contribution of money, property, effort, knowledge, skill or other assets to the joint venture. ... Pursuant to subsection 167(1.1), even if an election is in effect, tax continues to be payable on the following taxable supplies made under the agreement: •   supply of a service that is to be rendered by the supplier; •   supply of property by way of lease, licence or similar arrangement; and •   supply by way of sale of real property when the recipient is not a registrant. ...

. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. Ken Syer Quality Assurance Unit Excise & GST/HST Rulings Directorate Security Classification- Classification de sécurité Our File- Notre referenceYour File- Votre reference 4537812834 Dave Caron Aboriginal Affairs Unit Excise & GST/HST Rulings DirectorateDate August 27, 2003 Subject: Clarification of TIB B-039R's Delivery Requirement The following clarification for the delivery of property to an Indian at a location on reserve concerns XXXXX. ... Dave Caron Manager Aboriginal Affairs Unit Public Service Bodies & Governments Division Excise & GST/HST Rulings Directorate ...

The following facts have been obtained concerning the transactions between XXXXX and XXXXX •   XXXXX is a non-resident corporation incorporated in the XXXXX. •   XXXXX provides XXXXX services on behalf of XXXXX •   XXXXX contracts with a Canadian company, XXXXX to provide telemarketing services. •   These telemarketing services consist of XXXXX contacting people throughout XXXXX to solicit orders for XXXXX[.] When telemarketing calls are successful, they are relayed to the appropriate office in XXXXX and the applicable XXXXX is carried out by the operator responsible for that market. •   When XXXXX invoices XXXXX for the supply of the telemarketing services, the totals are shown in XXXXX XXXXX pays for these services XXXXX[.] •   Although XXXXX has an administrative office in XXXXX all the services are performed in XXXXX and all revenue is generated in XXXXX[.] ... Ryhorchuk Quality Assurance Unit 11735-15 11783-2/Ss.167(1) & (1.1) HQR0000316 ...

Statement of Facts: In your facsimile transmission you provide the following example for our review and response. •   XXXXX has a direct leasing division (the "lessor") where an individual customer (the "lessee") may lease a vehicle directly from the lessor; •   A car dealership (the "dealership") is prepared to sell a new vehicle to the lessor and accept the lessee's used vehicle as a trade-in. The lessee is not registered for the GST; •   The lessee will, in turn, lease the new vehicle from the lessor based on the following lease amount: Dealership's selling price of the new vehicle $49,500 Lessee's trade-in value (amount credited)   10,800 Lease amount $38,700 Your question is whether the GST charged to the lessor by the dealership should be calculated on the difference (i.e, 7% x $38,700 = $2,709) or on the full purchase price of the new vehicle (i.e., 7% x $49,500 = $3,465). ... Jones Director General Applications Division GST Rulings and Interpretations Directorate GAD #: 3113 (GEN) c.c.: M. ...

12 March 1996 GST/HST Interpretation 11915-7[1]- GST Status of Commercial Truck Driver Training Services Unedited CRA Tags ETA Sch V, Part III, 6; ETA Sch V, Part III, 8; ITA 118.5(1) XXXXXXXXXX File: 11915-7(DRM) Doc: 1168 Ref: V/III/6 & 8March 12, 1996 Subject: XXXXX I refer to the email transmission of March 10, 1995, from XXXXX to Mr. ... The company conducts courses in the following: •   XXXXX- the course is intended to prepare an individual to receive a class two driving licence, which permits a person to drive heavy solid frame trucks on a commercial basis. •   XXXXX- the course is intended to prepare an individual to receive a licence to train commercial bus drivers. •   XXXXX- the course is intended to prepare an individual to receive a class one driving licence, which permits a person to drive a tractor trailer truck on a commercial basis. •   XXXXX- the course is intended to prepare an individual who already has a class one licence to receive a a class two licence. •   XXXXX- the course leads to a certificate issued by the organization, attesting to the competence of the individual to practice the occupation of freight handler/warehouser. •   XXXXX- this training leads to a certificate issued by the organization, attesting to the competence of individuals to practice the occupation of off-road heavy truck driver. ... Venne Director Special Sectors GST Rulings & Interpretations c.c.: J. ...

30 October 1997 GST/HST Interpretation HQR0000654- Subsection 177(1.1) of the Excise Tax Act Unedited CRA Tags ETA 177(1.1)                                                                         GST/HST Rulings and  Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario  XXXXX                                                                                K1A 0L5  XXXXX 1055 Dunsmuir Street P.O. ... Facts •   An agent, who is a registrant and who is not an auctioneer, and a principal, who is required to collect tax in respect of a supply otherwise than as a consequence of paragraph 177(1)(d) of the Excise Tax Act (the "Act"), jointly elect under subsection 177(1.1) of the Act, to account for the tax collectible on a taxable supply as if the tax were collectible by the agent. •   The agent, in making the taxable supply in the course of its commercial activities on behalf of the principal, accounts for the tax collectible on the supply in its net tax and remits any positive amount of net tax. •   The supply is not a zero-rated supply. •   The agent records an accounts receivable in its books and records for the consideration and the tax payable by the recipient. •   At a future date, the accounts receivable is determined to be uncollectible; the agent writes off the bad debt in his/her books of account. •   The supply is made after April 23, 1996. •   The principal, the agent and the recipient are dealing at arm's length. ...

I understand that: •   XXXXX is registered for GST/HST purposes. The registration is issued to XXXXX with XXXXX as a trading name. However, from the information you have provided, it appears that the registration should have been issued in the names of XXXXX, with XXXXX as a trading name. •   XXXXX will be custom grazing approximately XXXXX head of cattle, which are owned by XXXXX[.] •   At the end of the grazing season, XXXXX will invoice XXXXX or the use of the pastureland during the term of the agreement XXXXX calculated at XXXXX per acre. •   At the end of the grazing season, XXXXX will also invoice XXXXX for labour expenses of its employees utilized by XXXXX during the term of the agreement. •   When invoicing XXXXX will calculate the consideration for the supply of its services based on XXXXX per pound of gain. ... Legislative References:           Subsection 136(1), Paragraphs 142(1)(d) and 142(1)(g), Section 144.1, Schedule VI, Part IV, sections 2.1 and 9, Schedule IX, Part IV, section 1, Schedule IX, Part V, section 2 Department of Finance Press Release dated June 24, 1991 GST Q & A 4j.36 Income Tax Interpretation Bulletin IT-156R dated 900112- Feedlot Operators NCS Subject Code:                 11720-1 ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The following information was provided in your letter to us: • XXXXX; • Corporation W's members are XXXXX including XXXXX which is a non-share capital corporation that is not registered for the GST/HST; • XXXXX; • XXXXX has entered into a funding agreement with a Crown Corporation in order to partially fund the costs associated with a specific project; • XXXXX is responsible for arranging and administering the project financing; • the Crown Corporation stipulates that XXXXX "will use some or all of the contribution to pay capital asset purchase and installation costs incurred by:" Corporation W; • Corporation W "will own the capital assets so purchased and installed"; • Corporation W must sign an acknowledgment and agreement that they will hold the project assets for a minimum of XXXXX years and will not sell, relocate or otherwise dispose of the assets except with the prior written consent of the Crown Corporation and XXXXX; • Corporation W must also sign and agree, that should they intend to discontinue the service that is the subject matter of the project, they will donate and transfer the project assets to XXXXX or to a third party designated by XXXXX and the Crown Corporation; • XXXXX is in the process of purchasing the project assets and is paying the GST/HST on such purchases; • XXXXX; • Corporation W is taking possession of the assets directly and the only involvement of XXXXX is receiving the funds from the Crown Corporation, ordering the assets that Corporation W needs and paying for the said assets. ...