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INTERPRETATION REQUESTED You have provided a specific fact scenario: * Company A has global operations which include Canada. Insurance decisions are made from Company A’s global head office located outside of Canada. * Company A engages insurance broker AA’s local office to place its entire insurance program. * Company A works with insurance broker AA to design, manage and place all insurance for its global operations. * Insurance broker AA obtains all underwriting information for Company A’s global operations and places the insurance on a global basis. * Insurance broker AA works with its Canadian affiliate insurance brokerage, insurance broker BB, to manager certain aspect of the insurance policies for Company A’s Canadian operations. ... The fact scenario given would fall within the scope of a common situation occurring in the industry […], that being where: * more than one broker is involved in a placement, and * the coverage is provided by an insurer licensed in Canada, * with a licensed Canadian broker shown on the policy. ...

When a subject vehicle is sold to a purchaser by a vendor and the purchaser exports the subject item, a rebate of the luxury tax is payable to the vendor if: * the vendor is a registered vendor for the purposes of the luxury tax; * the purchaser is not a registered vendor for the purposes of the luxury tax; * the luxury tax on the sale was payable and reported by the vendor; * the subject vehicle was not used in Canada before being exported; * the subject vehicle was not registered with the Government of Canada or a province before being exported; * the purchaser exports the subject vehicle as soon after the sale is completed; and, * the purchaser provides to the vendor, and the vendor retains, evidence satisfactory of the exportation of the subject vehicle by the purchaser. ... A qualifying sale is a sale of: * a subject vehicle to a purchaser; * the subject vehicle that has never been registered with the Government of Canada or a province; and, * the subject vehicle is sold for an amount that exceeds the price threshold of $100,000. A qualifying importation is an importation of: * a subject vehicle by a person; * the subject vehicle has never been registered with the Government of Canada or a province; and, * the value of the subject vehicle at the time of importation exceeds the price threshold of $100,000. ...

When a subject vehicle is sold to a purchaser by a vendor and the purchaser exports the subject vehicle, a rebate of the luxury tax is payable to the vendor if: * the vendor is a registered vendor in respect of subject vehicles; * the purchaser is not a registered vendor in respect of subject vehicles; * the luxury tax on the sale of the subject vehicle was payable and reported by the vendor; * the subject vehicle was not used in Canada before being exported; * the subject vehicle was not registered with the Government of Canada or a province before being exported; * the purchaser exports the subject vehicle as soon after the sale is completed; and, * the purchaser provides to the vendor, and the vendor retains, evidence satisfactory of the exportation of the subject vehicle by the purchaser. ... A qualifying sale is a sale of: * a subject vehicle to a purchaser; * the subject vehicle has never been registered with the Government of Canada or a province; and, * the subject vehicle is sold for an amount that exceeds the price threshold of $100,000. A qualifying importation is an importation of: * a subject vehicle by a person; * the subject vehicle has never been registered with the Government of Canada or a province; and, * the value of the subject vehicle at the time of importation exceeds the price threshold of $100,000. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Key features include the following: •   Over 60 user selectable display formats (for example, temperature, 4 or 8 digits displays of time, blinking digits); •   Up/down elapsed time; •   Up to 99 alarm settings; •   Optional alert horn may be used to signal work and break times; •   May be used as stand-alone time displays; •   Can connect with any number of clocks to form a synchronized network; and •   Aluminum frame with special hangars for mounting. ... Yours truly, Pauline Greenblatt Rulings Officer Excise Duties and Taxes Division Excise and GST/HST Rulings Directorate 2006/02/29 — RITS 65232 — Partial Exemption of Excise Tax for Oil Drilling Businesses in Western Canada ...

. / 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. Excise Tax and Fuel Charge Division Place de Ville, Tower A, 5th Floor 320 Queen Street Ottawa ON K1A 0L5 [Client] [Client Address] RITS: 9000236 August 15, 2024 Subject: EXCISE INTERPRETATION – Eligibility for Refund of Excise Tax Thank you for your letter of September 22, 2023 to the Canada Revenue Agency (CRA), concerning your eligibility for relief from the excise tax on fuel pursuant to section 68.17 of the Excise Tax Act (the Act) and the Ships’ Stores Regulations (the Regulations). ...

We understand that you are preparing to respond to [...] concerning excise duty amounts on imported cigars. The [...] apply to importations that occurred between [mm/dd/yyyy] and [mm/dd/yyyy] (the importation period). ... Therefore, depending on the date of importation, one of three rates would have applied: • From July 1, 2003 to June 30, 2006, inclusive, the rate applicable to imported cigars was $14.786 per 1,000 cigars. • From July 1, 2006 to December 31, 2007, inclusive, the rate applicable to imported cigars was $16.60 per 1,000 cigars. • As of January 1, 2008, the rate applicable to imported cigars is $18.50 per 1,000 cigars. ...

. / 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. Excise and Specialty Tax Directorate 5th floor, Tower A, Place de Ville 320 Queen Street Ottawa ON K1A 0L5 Addressee Case Number: 9000237 Attention: [Client] January 23, 2025 Dear [Client]: Subject: Interpretation – Fuel charge exemption certificates and rebate for fuel charge overpayment Thank you for your letter of [mm-dd-yyyy], concerning the application of the Greenhouse Gas Pollution Pricing Act (the Act) to a person’s eligibility for a rebate of an overpayment of the fuel charge. ...

Under paragraph 55(3)(a), a person may register as a distributor in respect of a type of fuel if the person carries on the business of selling, delivering or distributing fuel of that type and, in the ordinary course of that business, delivers fuel of that type in a listed province to any of the following: * another person for the purpose of resale, in the ordinary course of business, by the other person, * a registered distributor in respect of that type of fuel, * a farmer at a farm if the fuel is qualifying farming fuel, * a fisher if the fuel is qualifying fishing fuel, * a registered specified air carrier in respect of that type of fuel if the fuel is qualifying aviation fuel, * a registered specified marine carrier in respect of that type of fuel if the fuel is qualifying marine fuel, * a registered specified rail carrier in respect of that type of fuel if the fuel is qualifying rail fuel, * a registered emitter at a covered facility of the registered emitter, * a registered user in respect of that type of fuel, or * to another person if the fuel is, in accordance with the Ships’ Stores Regulations, designated as ships’ stores for use on board a conveyance of a class prescribed under those regulations. ... Section 20 of the regulations, for purposes of paragraph 55(3)(c) of the Act, allows an operator of a […] facility to register as a distributor in respect of a fuel that is a qualifying […] fuel if that operator carries on the business of selling, delivering or distributing fuel of that type, in a listed province to a […], that is their customer, at the operator’s […] facility. This permits the operator of the […] to register as a distributor and provide relief from the fuel charge to the […] when qualifying fuel is delivered to that […] through their […], and the delivery is subject to an exemption certificate in accordance with the Act. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... In doing so the officer may: •   Enter any place (subject to special rules in place for dwellings) the officer reasonably believes that activities subject to the Act may be carried on; •   Stop a conveyance and inspect or examine it (for compliance with the Act); •   Require an individual to be present, answer questions, and provide reasonable assistance during the inspection, audit or examination; •   Open any receptacle (or container) that the officer reasonably believes may contain anything to which the Act applies; •   Take samples of anything without charge; and •   During an inspection, audit or examination, and at or in that place, an officer may seize anything •   the officer reasonably believes was used as a means of contravening the Act, or •   the officer reasonably believes was used in relation to a contravention of the Act. ... Yours truly, Stan Loach Excise Duty Operations- Tobacco Unit Excise Duties and Taxes Division Excise and GST/HST Rulings Directorate 2006/05/23 — RITS 78827 — Digital Up Timer ...

. / 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. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 155936 Business Number: [...] ... We understand the following facts: • [...] ([...][the Company]) has formulated a fuel creation process for the production of certified clear diesel. • The process involves the combination of standard diesel fuel with water in a [...] ratio using special equipment. • [the Company] does not have any bulk plants or refinery locations. • All fuel is physically processed on the sites of [the Company]'s customers. • [the Company] rents the equipment to their customers and the customers solely purchase and own the input fuel, input ingredients, and the output diesel created. • Included in the rental cost, [the Company] provides staff to operate and maintain the equipment on the customer's sites. • [the Company] charges a fee for every litre of output fuel created by the customer. ...