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SUMMARY OF FACTS On [mm/dd/yyyy], a ruling was issued under case […] [A] to […] (the “Purchaser”) who, under […] (the “Agreement”), purchased a park model trailer situated on lot #[…] at […], [which is operated by the Corporation], for $[…] plus HST. Under the Agreement, the GST/HST on the sale of the park model trailer was collected by […] (the Agent), […]. ... The purchase of the […] park model trailer under the Agreement by the Purchaser from […] [the vendors], through the Agent, is exempt from the HST under section 5.1 of Part I of Schedule V to the ETA. ...

(Footnote 1) 4. […] (Footnote 2) 5. The Centre’s mission is […] (Footnote 3). […]. 6. Health care services at the Centre are provided by […] 7. […] 8. […], the Centre provides the following services and programs (Footnote 4): 9. […] 10. ... The Centre currently claims PSB rebates of 50% of the GST and federal part of the HST, and 82% of the provincial part of the HST, as a “charity”. 15. […]. […] (Footnote 5) 16. [...]. ...

You […], along with […](the “Co-owners”), own a […][yyyy model […] travel trailer] (VIN [#])[the Trailer], […]. 2. […][The Trailer] was acquired on [mm/dd/yyyy], from […] (the “Vendor”). 3. […]. 4. […]. 5. ... You and the Co-owners are not in the business of buying and selling personal property […]. 7. ... If you require clarification with respect to any of the issues discussed in this letter, please call me directly […]. ...

In the Plan document you provided, the Employer is […] responsible […] for the operation and administration of the Plan. […]. 5. […]. 6. […]. ... In [yyyy], […] ([…], (the Insurer)), as funding agent, issued […] (the Policy) to the Employer. ... Under […] the Policy, the Insurer will […][regularly provide to the] Employer a report […] outlining financial activity under the Plan. ...

. / 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. ... You [ask how] […] the GST/HST [applies] to the sale of copper IUDs […]. 2. […]. 3. […]. ... If you require clarification with respect to any of the issues discussed in this letter, please call me directly at […]. ...

The Park is located at [...] in [Community 1], in the municipality of [...], [...] ... In [yyyy] you began leasing site # [...] in that section of the Park that permits longer term stays under an annual lease arrangement. ... You purchased your unit, [....] park model trailer, in [yyyy]. The trailer measures [...]' x [...]'. ...

According to the APS: a) the Assignor was required to pay, to the Vendor, a purchase price in the amount of $[…] for the Unit; […][GST/HST] was not included in the price. b) the Assignor was required to pay, to the Vendor, a total deposit amount of $[…] in four installments: (i) Initial: $[…] (that is, [#]% of the purchase price) due at the time the APS is accepted by the Vendor; (ii) Second: $[…] (that is, [#]% of the purchase price) due on the later of [mm/dd/yyyy] and the [#] business day after the delivery of a document entitled Amendment to the Purchaser; (iii) Third: $[…] (that is, [#]% of the purchase price) due on [mm/dd/yyyy]; and (iv) Fourth: $[…] (that is, [#]% of the purchase price) due on [mm/dd/yyyy]. c) the Assignor was required to pay, to the Vendor, the balance of the purchase price (presumably, $[…], subject to closing adjustments including [GST/HST]) on the closing date. 6. The total deposit amount (that is, $[…]) was paid by the Assignor. 7. ... According to the Assignment Agreement, the Assignor’s Statement of adjustments and the Assignor’s signed direction to […](the Assignor’s legal representative) entitled “Order to pay”: a) the Assignee was required to pay, to the Assignor, an assignment amount of $[…] for the assignment of his rights in the APS. $[…] was payable as a deposit and the remaining balance of $[…] was payable to the assignee’s solicitor within [#] business days of receiving the fully executed assignment contract signed by the Vendor, and to the assignor’s solicitor within [#] business days of receiving the fully executed assignment contract signed by the Vendor; b) the assignment amount included an amount to reimburse the Assignor for the Deposit of $[…] that was paid according to the APS, thus the Assignor’s profit before assignment fees and commissions was $[…]; c) the Assignor was required to pay, to the Vendor, an assignment and filing fee totalling $[…]; d) the Assignor was responsible for paying real estate commission to both the listing and selling agents in respect of the assignment of the Assignor’s rights in the APS, which was a total of $[…]; e) the Assignor’s accountancy fees, $[…], and legal fees and related disbursements, estimated to be $[…], totalled $[…]; f) the Assignor’s loss after fees and commissions was $[…]; and g) the assignment amount (that is, $[…]) was inclusive of any [GST/HST] payable with respect to the assignment of the Assignor’s rights in the APS, and the Assignor must remit any [GST/HST] payable. 13. ...

Statement of Facts Our understanding of the facts based on your letter and our subsequent telephone discussions is as follows: •   XXXXX is a non-resident vendor of goods based in XXXXX, US. •   XXXXX acquires the goods on a delivered in Canada basis from XXXXX, a GST/HST registered non-resident company. •   The goods acquired by XXXXX are manufactured and packaged in XXXXX US. by XXXXX and delivered to XXXXX on a FOB XXXXX basis. •   XXXXX has contracted with XXXXX to store the goods until they are sold. •   XXXXX has XXXXX Canadian clients for the goods XXXXX. ... The factors to consider in determining whether, for GST/HST purposes, a non-resident person is carrying on business in Canada in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed, and •   the place of manufacture or production. ... Yours truly, Jeff Frobel Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2007/01/10 — RITS 82341 — Eligibility to Claim Input Tax Credits (ITCs) in Respect of Hedging Activities ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Its purpose is to: •   XXXXX; •   XXXXX; •   XXXXX. 6. The XXXXX has received grants of various amounts from the Consolidated Revenue Fund (the Funding) upon the requisition of the XXXXX. ... Yours truly, Debra Murphy Charities, NPO & Educational Services Unit PSB & Governments Division Excise and GST/HST Rulings Directorate XXXXX 2006/03/10 — RITS 46083 — Importation of Donated Works of Art XXXXX ...

The Product is available in [various] blends, namely, […]. 5. You provided a sample of […][blend 1], which has the following ingredients: […]. 6. ... The manufacturer’s website describes […][blend 1] as follows: […]. 10. […]. 11. In physically examining the contents of […][blend 1], it can be described as […], small […] grains, with flax seeds […]. 12. ...