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Response •   The provision of the engineering service is not within the ambit of subsection 162(1) and is therefor a taxable supply; •   The time of supply is deemed to be at the time the contract is entered into; •   Tax is due at the earlier of the day the consideration is paid or becomes due; •   The provision of subsection 168(2) is operative such that tax becomes payable on each payment. ... Research •   Letter of XXXXX •   P-128 •   P-110 •   Explanatory notes 4. Carlson & Associates Advertising Ltd v The Queen ...

. / 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. ... The Class B Limited Partner’s only activity is its investment in the Partnership; it is not a member of the Partnership Advisory Committee. 4) Pursuant to section […] of the Partnership Agreement, in addition to the distributions to be made pursuant to sections […], […] and […] of the Partnership Agreement when a general partner resigns or is removed, or the Partnership is sold or dissolved, the Partnership will, subject to section […], make a distribution to the holders of Class B Units and Class C Units (the “Priority Distribution”) in proportion to their ownership of Class B Units and Class C Units equal to an undisclosed specified percentage per annum of an undisclosed factor. 5) Pursuant to section […] of the Partnership Agreement, the general partner is required to make distributions to the partners from time to time- that is, essentially all sums received from eligible investments, net of: the payment or reimbursement of the partnership expenses, which includes the payment of management fees, […] and other types of fees pursuant to section […], and the payment of the Priority Distribution. 6) Section […] of the Partnership Agreement provides that amounts distributed shall be distributed to the partners as follows: * first, to the holders of Class B Units and Class C Units in proportion to their ownership of Class B Units and Class C Units, until such time as the holders of Class B Units and Class C Units have received all due and unpaid Priority Distributions; * as to the balance: […]% to the general partner and […]% to the limited partners in proportion to their ownership of Class A Units. ... You state that the management fee payable to the Manager under the Management Agreement and referenced in section […] of the Partnership Agreement is subject to the GST/HST. ...

[Country X] claimed a FCTIP rebate of $[...] as the organizer of a foreign convention. [...]. * A list of the attendees for the meetings that took place at [City 1, Province 1] during the period from [mm/dd/yyyy] to [mm/dd/yyyy]. ... All the attendees were non-residents. * [...] the purpose of the meetings was for [Company B] and [Company C] to host their [...] clients so that they could showcase their [...] products to them. * The program agenda for the meetings that took place during [...]. [...]. ... The [...] program agenda that was provided in your submission includes only [#] meetings for the [clients]: [...] to discuss, showcase and train the [clients] on the new products that [Company B] and [Company C] are offering. ...

VI, partie V, 1(c)                                                                         Téléphone no: (613) 954-8585                                                                         Télécopieur no: (613) 990-1233                                                                         HQR0000360                                                                         Alinéa 1c), partie V, annexe VI                                                                         Fichier #: 11640-4(dc) XXXXX le 29 mai 1997 XXXXX Cher Monsieur, La présente fait suite à la demande de renseignements présentée par XXXXX de XXXXX le 15 octobre 1996, par rapport à la position de notre Ministère concernant l'application de l'alinéa 1c) de la partie V de l'annexe VI de la Loi sur la taxe d'accise (la Loi) aux différents procédés effectués par les commerçants de peaux d'animaux. ...

On the label, one can find the following indications: •   real milk chocolate with roasted almonds for fondue or real milk chocolate for fondue •   recipe for two servings of chocolate fondue: XXXXX 35% cream XXXXX chocolate (with or without almonds) fresh fruits Slowly warm up cream. ... The wrapper carries the following information: On the front of the label: •   The weight of the bar- XXXXX •   The price- XXXXX •   The message XXXXX •   XXXXX •   All of the above text messages are provided in English and French •   Prominently displayed is the name of an organization "XXXXX XXXXX and the phrase XXXXX •   The website for the group XXXXX On the back of the label: •   The fondue recipe described above •   XXXXX •   The address of the organization featured on the front is enclosed in a box: XXXXX •   the phrase "Made in Canada" along with a Maple Leaf symbol •   A list of ingredients and allergy information •   With the exception of the address, all the information is provided in English and French Interpretation Requested You are asking us to confirm that the supply of the above-described bars of chocolate is considered not taxable under the GST/HST. ... For your information, I am enclosing a copy of our current publication, Ch. 4.3 " Basic Groceries ", since Memorandum 300-3-3, which you referred to in your letter, is now obsolete. ...

On [mm/dd/yyyy], [...] (the Individual) entered into a purchase and sale agreement (the Purchase Contract) with [...] ... On [mm/dd/yyyy], the final statement of adjustments was approved and became effective; it includes the following information: * Buyer- the Company, as bare trustee and nominee of the Individual; * Adjustment date- [mm/dd/yyyy]; * Completion date- [mm/dd/yyyy]; and * Possession date- [mm/dd/yyyy]. 5. ... The Real Estate Appraisal Division of CRA has provided the following information: * [...]- transfer of the Property from the Vendor to the Company, dated [mm/dd/yyyy]; * [...]- the borrower is the Company; digital signature is the Individual, as authorized signatory of the Company; * [...]- transferor/borrower/party is the Individual, as Covenantor (see below); * [...], includes the following:- borrower/mortgagor is the Company;- the Individual is "Covenantor"; the terms of the [...] provide, in part, that the Covenantor will pay or cause to be paid to the Mortgagee all amounts owing by the Mortgagor; to unconditionally guarantee full performance and discharge of all obligations of the Mortgagor; that the Covenantor is jointly and severally responsible with the Company. 7. [...]. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... In sample transaction #3, the service provider's invoice to XXXXX details the activities of the service provider for a report as follows: Chart review: 6.00 hrs. @ $287.00/RD. = $1,722.00 Preparation time for discussion with insurance claimant: 0.50 hrs. @ $287.00/RD. = $   143.50 Discussion with insurance claimant: 0.75 hrs. @ $287.00/RD. = $   215.25 Preparation of final report: 2.00 hrs. @ $287.00/RD. = $   574.00 Subtotal: $2,654.75 GST: $   185.83 Total: $2,840.58 19. ... Yours truly, Susan Eastman Municipalities and Health Care Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2006/08/31 — RITS 51877 — [XXXXX Grass Supplied as a Forage Crop] ...

In their letter, XXXXX provided the following information: •   XXXXX choose their own locations, which appear profitable based on traffic flow and availability of ABMs in the surrounding area. •   XXXXX negotiated an agreement with the location owner to allow for the installation of an ABM for which they pay a portion of the applicable surcharge amount. •   The surcharge amount varies from XXXXX per withdrawal based on the affordability and need of customers using the ABM. •   XXXXX. fills the ABM with their own cash from their business account. ... In XXXXX opinion, they should be allowed to claim ITCs on the purchase of the equipment to get started in its XXXXX venture because the ABM operations business was started with the following objectives in mind: •   To purchase and install ABMs at potentially profitable locations, establish the business with a view to improve the transaction volume and then find suitable customers who would buy their ABMs along with an established location and pay a certain price which would provide a sizeable profit. •   XXXXX[.] •   XXXXX[.] ... In a letter XXXXX provided to the CCRA, XXXXX confirmed having sold XXXXX ABMs, which according to the documentation we have were placed in the following retail locations: •   XXXXX •   XXXXX •   XXXXX •   XXXXX As for the current status of the ABMs, XXXXX wrote a letter to the CCRA stating that the ABM at XXXXX and the other XXXXX locations were being offered for sale to potential buyers. ...

. / 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. ... Pursuant to this subsection, • if the tax amount calculated includes a fraction of a cent and the fraction is less than half of a cent, the fraction may be ignored; and • if the tax amount calculated includes a fraction of a cent and the fraction is equal to or more than half of a cent, the fraction must be increased to a full cent. ... As such, either of the following calculations is acceptable. $31.95 x 13% = $4.1535 = $4.15 $31.95 x 5% = $1.5975 = $1.60 $31.95 x 8% = 2.5560 = 2.56 $4.16 Subsections 165.2(1) and (2) read as follows: 165.2 (1) Calculation of tax on several supplies- Where two or more taxable supplies are included in an invoice, receipt or agreement and tax under section 165 is imposed in respect of each of those supplies at the same rate or rates, the tax payable in respect of those supplies, calculated on the consideration for those supplies that is included in the invoice, receipt or agreement, may be calculated on the total of that consideration. (2) Rounding of tax- Where tax that is at any time payable under this Division in respect of one or more supplies included in an invoice, receipt or agreement is an amount that includes a fraction of a cent, the fraction (a) if less than half of a cent, may be disregarded for the purposes of this Part; and (b) if equal to or greater than half of a cent, shall be deemed, for the purposes of this Part, to be an amount equal to one cent. ...

To determine the provincial part of the HST, multiply the HST paid or payable by: • 7/12 for those purchases taxed at 12%; • 8/13 for those purchases taxed at 13%; • 9/14 for those purchases taxed at 14%; • 8/14 for those purchases taxed at 14% before the 2008 rate change; or • 10/15 for those purchases taxed at 15% after the 2010 Nova Scotia rate change. ... For example, a charity is resident in [Participating Province A] and [...] ...