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Interpretation Given When supplied by a vocational school, the following are exempt supplies: •   Ground school training, dual and solo flight times for the Commercial Pilot Licence (Aeroplane) and the Airline Transport Pilot Licence; and •   Ground school training, dual and solo flight times for the following Ratings: •   multi-engine rating; •   instrument flight rating; •   VFR Over-the-Top rating; •   night rating; •   sea plane rating; •   land plane rating; and •   flight instructor rating[.] ... It is the position of CCRA that the following programs develop or enhance students' occupational skills: •   Commercial Pilot Licence (Aeroplane); •   Airline Transport Pilot Licence; •   VFR Over-the-Top rating; •   night rating; •   multi-engine rating; •   instrument flight rating; •   sea plane rating; •   land plane rating; and •   flight instructor ratings. ... (d) Classes or Ratings in Respect of Pilots' Licences The solo and dual flight time required by federal legislation for the following ratings is exempt under section 8: •   multi-engine rating •   instrument flight rating •   VFR Over-the-Top rating •   night rating •   sea plane rating •   land plane rating The federal legislation sets out 4 different classes of flight instructor rating. ...

The following information in addition to that provided and contained in our previous interpretations was provided in your letter and our subsequent telephone conversations: •   XXXXX administers musical copyrights on behalf of their clients, some are resident in Canada and others are not. •   XXXXX supplies rights to music copyrights administered and/or owned by them to sub-publishers (SP) located in foreign jurisdictions in order to facilitate the collection of royalties generated outside Canada. •   The supply of the copyrights include performing rights and reproduction rights. •   The SP's collect public performance royalties (for radio and TV play) and mechanical royalties (for CD sales) generated for uses of the musical property earned in these foreign jurisdictions. ... Frobel Border Issues Unit General Operations and Border Issues Division GST/HST Rulings and Interpretations Directorate c.c.: Jeffrey Frobel,   General Operations & Border Issues Division,   Borders Issues Unit Ivan Bastasic,   General Operations & Border Issues Division,   Borders Issues Unit Raymond Labelle,   General Operations & Border Issues Division   Services and Intangibles Unit XXXXX XXXXX Legislative References: Subsections 142(1), 142(2), 177(2) of the Act Section 10 of Part V of Schedule VI to the Act NCS Subject Code(s): 11640-2, 11680-1 ...

CANCO derives its revenues from supplying the following services: •   Setup fee- A one-time fee charged to set up an account. •   Monthly account fee- A monthly service fee charged to maintain the status of the account. This service includes: real-time transaction processing, WebPOS terminal, batch processing, and recurring billing services. •   Merchant accounts discount- A charge based on a percentage of credit card dollar volume processed. •   Shopping Cart fees- A monthly fee charged for using CANCO's shopping cart services. •   Various fees charged per transaction or instance (for some customers some of the services listed below may be included in the monthly account fee): •   Transaction processing. •   Pre-authorized transactions. •   Electronic funds transfer between financial institutions. •   Transaction and sales analysis. •   Fraud screening. •   Address correction. •   Inventory management. •   Demographics information. ...

1 February 1996 GST/HST Interpretation 11705-4- The Requirements for the Disclosure of Tax Under the Excise Tax Act (the Act) Unedited CRA Tags ETA 223(1)                                                                         Facsimile #: (613) 990-1233                                                                         File no.: 11705-4(FP)                                                                         S. 223(1)                                                                         XXXXX Dear XXXXX This is in response to your meeting with this Department on February 6, 1992 and your phone conversation with François Paris of my staff on February 8, 1996 regarding the requirements for the disclosure of tax under the Excise Tax Act (the Act). ... Jones Director General Applications Division GST Rulings and Interpretations Policy and Legislation Branch GAD #: 2718 (GEN) c.c.: All regions XXXXX M. ...

15 November 1996 GST/HST Interpretation 11690-8[1]- Registration of Non-Resident Corporation Unedited CRA Tags ETA 123(1) permanent establishment; ETA 132(2)                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 XXXXX                                                                                 File #: 11690-8(glr) XXXXX                                                                                 HQR0000122 XXXXX                                                                                 ss. 123(1), 132(2) XXXXX ATTENTION: XXXXX November 15, 1996 I refer to XXXXX E-mail message of August 9, 1996, concerning the eligibility of a XXXXX company, specializing in hospital software, to register for Goods and Services Tax (GST) purposes. XXXXX provided the following facts in his message: •   AXXXXX company specializing in hospital m.i.s.-software applications has an employee in Canada solely for the purpose of installing XXXXX-supplied software. •   The service of installing the software is included in the price of the software. •   The only additional billings for the employee's services will be for training or emergency support services (the likelihood of either is small to insignificant as "user-support" services are supplied from XXXXX either on-line or by telephone). •   The Canada-based employee works from an office in his home. ...

These additional sponsorship features include: a) Joint Venture Team (Cash sponsorship of XXXXX or more): •   full page advertisement in the final program; •   opportunity to XXXXX •   opportunity to make a brief presentation to conference delegates affirming sponsor's support of the XXXXX industry; •   five complimentary conference registrations, with an additional complimentary registration for each additional XXXXX •   opportunity to add XXXXX to the sponsor's Internet home page; •   opportunity to incorporate XXXXX into the sponsor's print materials; •   recognition in all media releases; •   all benefits of the XXXXX level (see below). b) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite (one night); •   complimentary exhibit booth XXXXX value); •   four complimentary registrations XXXXX value); •   early and final registration lists of delegates and exhibitors. c) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite XXXXX •   complimentary exhibit booth XXXXX value); •   three complimentary registrations XXXXX value); •   early and final registration list of delegates and exhibitors. d) XXXXX (Cash sponsorship of XXXXX •   complimentary exhibit booth XXXXX value); •   two complimentary registrations XXXXX value). e) XXXXX (Cash sponsorship of XXXXX •   one complimentary registration XXXXX value). 5. ... Furthermore, it is our ruling that the sponsorship payments are in respect of promotional supplies to which section 135 (see Explanation below) of the Excise Tax Act ("ETA") applies, and in respect of the following taxable supplies: •   conference registrations; •   exhibit booth; and •   hospitality suite. The following promotional supplies made by XXXXX in exchange for the sponsorships fall within the parameters of section 135 of the ETA: •   recognition of sponsor on conference signage; •   recognition of sponsor in promotional brochures; •   sponsor's profile included in the final conference program; •   sponsor's receipt of a full-page advertisement in the conference program; •   recognition of sponsor in conference media releases; •   sponsor's right to include information and promotional items in registration kits; •   sponsor right to use of XXXXX logo on sponsor's Internet home page; •   sponsor right to use of XXXXX logo in sponsor's print materials; •   sponsor's right to express registration and conference check-in (incidental); •   early and final registration lists of delegates and exhibitors (incidental), •   sponsor's right to chair sessions; and •   sponsor's right to make a presentation to delegates.   ...

Investors had made their investments under the assumption that ABC XXXXX would be in the leasing business and the company in anticipation of entering into the leasing business took the below actions: •   selected premises with a store front and lot necessary for a leasing operation; •   obtained contingent lessor's insurance in anticipation of leasing; •   became a member of various organizations and associations involved in leasing; and •   became a licensed as a dealer, which is required as a lessor, but not as a finance company. Initial expenses to start up the business consisted of the following examples: •   computer equipment; •   rental of space, •   renovation costs; •   utilities; •   legal and accounting; and, •   meals and entertainment. ...

X]. […] [Executor A’s] GST/HST account […] status […][is] currently “active”, […][Executor A’s] filing status is “non-filing”, and [Executor A’s] reporting period [is] “non-reporting”. […] [Executor A’s] business activity […][is reported] to be […]. 2. ... The Estate paid an Attorneyship fee of $[…] to [Executor A] […][around that same date and] remitted an amount of $[…] as HST directly to the Receiver General, by way of a bank draft ([…]). 5. ... The CRA deposited both of the above mentioned bank drafts on [mm/dd/yyyy], and the payments were posted to an account number […]. 7. […], the CRA received a completed General Application for Rebate of GST/HST (GST189) […] requesting a rebate of tax paid in error for a total of $[…] in respect of the […][amounts] remitted by the Estate as tax in respect of [Executor A's] Attorneyship fees [and] […] Executorship fees. 8. […]. 9. […]. 10. […]. 11. […][Subsequently], the Estate requested that the amount of the rebate request be increased to include also the $[…] remitted directly by the Estate as HST in respect of the Executorship fees paid to [Executor B], [thereby] increasing the rebate requested to $[…]. 12. ...

Travel Agency's books and records: Invoice to customer Air fare $500.00 HST     75.00 Total Air fare   575.00 Hotel Accommodation   200.00 GST     14.00 Total Hotel Accommodation   214.00 Total Payable by customer $789.00 Invoice to air carrier Commission earned $50.00 HST     7.50 Total Payable by air carrier $57.50 Invoice to hotel Commission earned $30.00 HST     4.50 Total Payable by hotel $34.50 Travel agency's GST/HST return: GST/HST collectible $12.00 Input tax credits (GST/HST paid out)    0.00 Total GST/HST remittance $12.00 Travel agency's statement of account: Total collected from customer on behalf of air carrier and hotel   789.00 Less commissions earned and applicable HST     92.00 Amount to be forwarded $697.00 Air Carrier's books and records: Revenues: Air fare $500.00 HST     75.00 Total Air fare $575.00 Expenses: Travel agency's commission on air fare $50.00 HST     7.50 Total Payable to travel agency $57.50 Air carrier's GST/HST return: GST/HST collectible $75.00 Input tax credits (GST/HST paid out)     7.50 Total GST/HST remittance $67.50 Hotel's books and records: Revenues: Hotel accommodation $200.00 GST     14.00 Total Payable by travel agency $214.00 Expenses: Travel agency's commission on hotel accommodation $30.00 HST     4.50 Total Payable to travel agency $34.50 Hotel's GST/HST return: GST/HST collectible $14.00 Input tax credits (GST/HST paid out)     4.50 Total GST/HST remittance $  9.50 The latter portion of each response will provide general statements on each scenario. ... Travel Agency's books and records: Invoice to customer Air fare $500.00 GST     35.00 Total Air fare   535.00 Hotel Accommodation   200.00 HST     30.00 Total Hotel Accommodation   230.00 Total Payable by customer $765.00 Invoice to air carrier Commission earned $50.00 GST     3.50 Total Payable by air carrier $53.50 Invoice to hotel Commission earned $30.00 GST     2.10 Total Payable by hotel $32.10 Travel agency's GST/HST return: GST/HST collectible $5.60 Input tax credits (GST/HST paid out)   0.00 Total GST/HST remittance $5.60 Travel agency's statement of account: Total collected from customer on behalf of air carrier and hotel $765.00 Less commissions earned and applicable GST     85.60 Amount to be forwarded $679.40 Air Carrier's books and records: Revenues: Air fare $500.00 GST     35.00 Total Air fare $535.00 Expenses: Travel agency's commission on air fare $50.00 GST     3.50 Total Payable to travel agency $53.50 Air carrier's GST/HST return: GST/HST collectible $35.00 Input tax credits (GST/HST paid out)     3.50 Total GST/HST remittance $31.50 Hotel's books and records: Revenues: Hotel accommodation $200.00 HST     30.00 Total Payable by travel agency $230.00 Expenses: Travel agency's commission on hotel accommodation $30.00 GST     2.10 Total Payable to travel agency $32.10 Hotel's GST/HST return: GST/HST collectible $30.00 Input tax credits (GST/HST paid out)     2.10 Total GST/HST remittance $ 27.90 General comments on Scenario 2: The customer is required to pay the HST and the GST. ... Portion of the price that is attributable to the air fare (supply made in Nova Scotia) $500.00 HST     75.00 Sub-total $575.00 Portion of the price that is attributable to the hotel accommodation, car rental and meals (supplies made in British Columbia): $   500.00 GST        35.00 Sub-total $   535.00 Total payable by customer $1,110.00 Invoice to tour operator Commission earned $100.00 HST     15.00 Total Payable by tour operator $115.00 Travel agency's GST/HST return: GST/HST collectible $15.00 Input tax credits (GST/HST paid out)     0.00 Total GST/HST remittance $15.00 Travel agency's statement of account: Total collected from customer on behalf of tour operator $1,110.00 Less commission earned and applicable HST      115.00 Amount to be forwarded to tour operator $   995.00 Tour Operator's books and records: Revenues: Tour package sold for $1,000.00 Portion of tour package where HST applies: ($1,000 x 50%) $   500.00 HST        75.00 Sub-total $   575.00 Portion of tour package where GST applies: ($1,000 x 50%) $   500.00 GST        35.00 Sub-total $   535.00 Total $1,110.00 Expenses: Travel agency's commission on tour package $100.00 HST  15.00 Total Payable to travel agency $115.00 Tour operator's GST/HST return: GST/HST collectible $110.00 Input tax credits (GST/HST paid out)     15.00 Total GST/HST remittance $  95.00 General comments on Scenario 5: The customer is required to pay the HST and the GST. ...

Facts Provided: •   Value of the new vehicle: $20,000 •   Value of the trade-in vehicle: $20,000 •   Lien on the trade-in vehicle: $18,000 •   Lease payments on the new vehicle: $300/mth Department's assumptions: •   The customer is a non-registrant and the dealer is a registrant; •   Lease period on the new vehicle: 48 months •   Residual value on the leased new vehicle: $8,000 •   Money factor (interest rate): 0.0% Response requested: (i) GST charged on the monthly lease payments- 7% x ($20,000- $20,000- $8,000) / 48 months: Nil Example #3: Accommodation sale. Facts provided: •   A non-registrant vendor wishes to sell their vehicle to a non-registrant purchaser; •   The vendor sells the vehicle to a dealer as a trade-in and purchases a new vehicle from that dealer; •   The dealer sells the trade-in vehicle to the purchaser; •   Sale price of the new vehicle: $20,000 •   Value of the trade-in vehicle: $  5,000 •   Sale price of the trade-in vehicle to the purchaser: $  5,000 Department's assumption: •   The dealer is registered for the GST. ... Facts provided: •   Purchase price of the new vehicle: $20,000 •   Residual value of the old leased vehicle: $  5,000 •   Value of the old leased vehicle: $  7,000 Department's assumptions: •   The non-registrant exercises the buy-out option on the old leased vehicle; •   The registered dealership accepts a trade-in of $7,000 for the old leased vehicle. ...