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24 November 1999 GST/HST Interpretation HQR0002004- Determining Who is the "Recipient" Where an Owner-Operator Uses a Freight Transportation Company's Credit Card to Obtain Supplies of Fuel and Truck Repair Services in Canada and the Tax Status of the "Chargebacks" to the Owner-Operator for these Supplies Unedited CRA Tags ETA 123(1) recipient; ETA 165(1); ETA 221(1) TO: XXXXX XXXXX XXXXX XXXXX FROM: Robert Bowman Technical Officer General Operations Unit GST/HST Rulings & Interpretations DirectorateFile HQR0002004 DATE: November 24, 1999 Subject: Determining Who is the "Recipient" Where an Owner-Operator Uses a Freight Transportation Company's Credit Card to Obtain Supplies of Fuel and Truck Repair Services in Canada and the Tax Status of the "Chargebacks" to the Owner-Operator for these Supplies I am writing in response to your request in which you have asked for our assistance concerning the application of the GST/HST. ...

Yours truly, Dwayne Moore Charities and Non-profit Organizations Unit Public Service Bodies & Governments Division GST/HST Rulings and Interpretations Directorate c.c.: D. ...

Section 1 of Part I of Schedule IX to the ETA defines the "place of negotiation" of a supply to be "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works... ...

The definition of "real property" in section 123 of the ETA includes, "... every estate or interest in real property, whether legal or equitable... ...