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Statement of Facts Our understanding of the facts, the transactions, and the purpose of the transactions, based upon XXXXX letter and discussions with both XXXXX and XXXXX, is as follows: •   XXXXX, XXXXX and the XXXXX are licencees under the EA and operate bonded warehouses; •   XXXXX and XXXXX supply their products "in-bond" to the XXXXX; •   It has always been the practice of XXXXX and XXXXX to invoice Canadian Liquor Control Boards and to include GST based on the duty and excise tax paid value of the goods shipped; •   XXXXX; •   XXXXX; •   Consequently, as at July 3, 2001, this had resulted in excess cash outflow of approximately XXXXX to XXXXX and XXXXX. Transaction(s) •   XXXXX and XXXXX supply their products "in-bond" to the XXXXX; •   XXXXX and XXXXX remit to the CCRA, GST based on duty-paid value of goods sold to the XXXXX; •   XXXXX. ... Explanation •   Pursuant to the Excise Act (EA), spirits are subject to excise duty, ascertained and levied at production; however, the duty is subject to deferral mechanisms such as transfers "in-bond", which generally defer the time when duty becomes payable until the spirits are "entered for consumption"; •   Pursuant to sub. 165(1) of the ETA, taxable "supplies" of goods are subject to GST/HST calculated upon the value of the "consideration" for the supply; •   Pursuant to s. 154, ETA, "consideration" includes any amount of excise duty that is "payable"; •   Canadian distillers, manufacturers and liquor boards are licencees under the EA and operate bonded warehouses; •   Canadian distillers generally supply their products "in-bond" to manufacturers and provincial liquor boards, deferring the payment of excise duty until the spirits are "entered for consumption" (usually, when they leave the final bonded warehouse in the supply chain); •   When spirits are "entered for consumption," excise duty becomes payable; •   Where spirits are supplied in circumstances where the duty is not yet payable (e.g. while in bond), the GST/HST payable in respect of the supply is calculated on the value of the consideration for the supply, excluding excise duty (i.e. the amount invoiced); •   Where spirits are supplied at a point in time after the excise duty becomes payable, the GST/HST payable is calculated on the value of the consideration for the supply that includes the duty. ...

The Corporation operates […][X] […] 5. […] 6. […] 7. […] 8. […] 9. Individuals wishing to apply for admission to […][X] must contact their regional Community Care Access Centre (CCAC). ... The Corporation’s […] Manual describes the roles and responsibilities of the Medical Director [at X]: […][Description of the roles and responsibilities of the Medical Director] 18. […], there are [#] physicians serving [X] […]. ... The Corporation is funded by the MOHLTC […]. […][More details about funding] […] 29. ...

. / 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. ... STATEMENT OF FACTS * Your company occasionally supplies real estate valuations for insurance claims. * You supplied two fire insurance reports to us as samples of your work: 1) […][Address in Canada], produced for […] and 2) […][Address in Canada], for […]. * The report for the first case stated at page [#]: “Property inspection –... ... In this particular situation – valuation services that concern property insurance claims – the service would be exempt under the definition of financial service in subsection 123(1) if it complied with paragraph (j.1) of that definition and was not excluded by paragraph (r). ...

[The Corporation] was continued under […] of […][Provincial Act Z] (Footnote 1). 2. ... The categories are: Category 1 – A body created by a government in legislation; Category 2 – A body incorporated by a government; and Category 3 – A body that meets the following criteria – (a) a government has taken action relating to the body; (b) the body is set up to undertake a public service function that government usually undertakes; and (c) the government retains the overall authority for the regulatory program, and the body remains accountable to the government. ... Yours truly, Desneiges Arbour Charities and Non-profit Organizations Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 […]. 2 […] 3 […] ...

The Facility is made up of [...] resident "home areas" with a total of [...] beds. ... [The Organization] has [...] attending physicians, including the medical director (who is also an attending physician). [...] physicians are onsite at [the Facility] on [...] mornings and [...] physician is onsite on [...] mornings. A [...] physician is onsite every other [...] or [...], or more frequently if required. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... XXXXX lists the following benefits of membership for all members: •   XXXXX; •   XXXXX; •   XXXXX; •   XXXXX; and •   XXXXX. 22. ... 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 2006/06/23 — RITS 78986 — GST/HST Status of XXXXX Herbal Teas ...

STATEMENT OF FACTS We understand the facts to be as follows: 1. […] (the Company) is a GST/HST registrant […]. 2. ... The back label of Product 1, in reference to the product, states […][description of product and health claims][…]- […] 100% medium chain triglycerides, […] 5. […]. 6. ... Furthermore, suggested use indicates to build from [#] teaspoon up to [#] tablespoon [#] times a day. ...

The commission is defined in Schedule [...]. Section [...] provides that the merchant agrees to honour the voucher as set out in Schedule [...] under [the Company's] standard Terms and Conditions in Schedule [...]. Section [...] indicates that the Product shall be sold in accordance with [the Company's] Standard Terms and Conditions (of Schedule [...]). ... It includes the stated dollar value (e.g., $[...]), the percentage of the discount from the face value (e.g., [...]%), the price (e.g., $[...]), minimum and maximum number of buyers, length of promotion, the date(s) of the promotion, [the Company's] percentage (e.g., [...]%), the merchant's expected net revenue per buyer (e.g., $[...]), merchant's name, product description, special conditions. ...

[Addressee] Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5   Case Number: 138581   Business Number: […]   March 12, 2013 Dear [Client]: Subject: GST/HST RULING Determining if an entity is a non-profit organization This is in response to […], concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to […] (the Corporation). ... The Corporation was established by […] dated [mm/dd/yyyy]. […] was issued pursuant to […](the Provincial Act) and[…](the Provincial Regulations). 2. ... Yours truly, Michael Mavis Government Sectors Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate     ...

[TourCo] operates "tour packages" (as that term is defined in the ETA) [...] 3. [...]. 4. [...]. 5. ... [the][individual] will be solely employed by the Subsidiary. [...]. 8. ... [foreign] bank account on an "as needed" basis. 13. [...] 14. [...] ...