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19 May 1995 GST/HST Interpretation 11845-3- GST Status of the Supply of Rolls of Netting Unedited CRA Tags SOR/91-39 Sch 2(2)(e)                                                                         C.N.: 1153 File: 11845-3 XXXXX  XXXXX This is further to your electronic mail message of February 28, 1995 received by Pam Lafrance, formerly of this office, regarding the application of the Goods and Services Tax (GST) to rolls of netting used in the aquaculture industry. ...

In that leasehold strata plan, this amount ranges from approximately XXXXX % of the purchase price of a strata lot to XXXXX %. ...

. / 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. ... Generally, section 174 of the ETA applies where a person pays a reasonable allowance to an employee, a partner, or where the person is a charity or a public institution, a volunteer: * to purchase property or services in Canada, all or substantially all, of which are taxable (other than zero-rated) supplies in relation to activities engaged in by the person, or * for the use in Canada, in relation to activities engaged in by the person, of a motor vehicle, and the allowance is deductible in computing the income of the person for purposes of the Income Tax Act (ITA) or would be deductible if the person were a taxpayer under the ITA and the activity were a business. ...

. / 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. ... However, subsection 261(1) would allow a supplier to apply for a rebate of tax remitted in error in specific situations, such as: • where the supplier has not collected GST/HST from a recipient in respect of an exempt or zero-rated supply but has, erroneously, remitted from its funds an amount as GST/HST on that supply; or • where the supplier has collected an amount of GST/HST from a recipient but has mistakenly remitted more GST/HST than was collected. ...

. / 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 DRC is applied at a rate of [#] cents per kilowatt hour (kWh) of electricity consumed in Ontario with the exception of the reduced rate service areas. ... “Large businesses” subject to the recapture rules in Ontario with respect to “specified property or services” are required to recapture the provincial component of the HST on “specified energy”. […] 7. ...

30 August 1995 GST/HST Interpretation 11680-5-3[1]- Interpretation- ETA s. 132- Unedited CRA Tags ETA 132(1)(b); ETA 132(3); ETA 145(1); ETA Sch VI, Part V, 7                                                                         Telephone: (613) 954-8585 Fax: (613) 990-3602 File: 11680-5-3(kpm) ss. 132(1)(b), 132(3), 145(1) sec 7/V/VI  XXXXX                                                                                August 30, 1995 I refer to your letter of January 24, 1995, requesting confirmation of several key points in your reply to XXXXX In addition to reviewing the contents of the previous correspondence, Karl Marten of my staff contacted the writer, XXXXX, for additional information. ... It is our view that the supply of the services by the general partner to the partnership is a taxable supply of services (provided the services supplied are not an exempt supply pursuant to Schedule V to the Act) and not provided as a result of "... an activity engaged in by a person as a member of a partnership... ... You requested our comments on whether the management services constitute a single or multiple supply — whether or not the management services constitute a single or multiple supply is a question of fact. ...

28 July 1997 GST/HST Interpretation HQR0000458- The Enlargement of Real Property by Way of Severance Unedited CRA Tags ETA Sch V, Part I, 9(2)(c)                                                                         25 McArthur Road, Place Vanier, 10th Floor, Tower C  XXXXX                                                                                Vanier, ON  XXXXX                                                                                K1A 0L5                XXXXX  XXXXX                                                                                Case: HQR0000458  XXXXX                                                                                NCS: 11950-1 July 28, 1997 Dear XXXXX This is in response to a letter from XXXXX of the XXXXX of December 4, 1996, with attachments, concerning the application of the Goods and Services Tax (GST) in regards to paragraph 9(2)(c) of Part I of Schedule V to the Excise Tax Act (the Act). ... Black's Law Dictionary (10th edition) defines "parcel" as follows: " A part or portion of land. ... VI/9(2)(c) [Act and explanatory notes], XXXXX IT-153R3, b.c.c.: Originator's Desk Copy NCS Subject Code(s) 1I             Registration Number: na District Chief, Audit H.Q. ...

21 February 1997 GST/HST Interpretation HQR77- Request for Assistance Related to Supplies Made Between Municipalities Unedited CRA Tags ETA Sch V, Part VI, 22 XXXXX File #: 118901(ON) XXXXX c.n. ... As stated in fact # 3 above, the purpose of the joint venture is to purchase and own land for sewage disposal lagoons. ... As stated in fact # 4, each town is to hold an undivided interest in the land as tenants in common. ...

Where this is not determinative of the place of supply, the supply may be regarded as being made in a participating province where: •   the place of negotiation for the supply is located in Canada, if the Canadian element of the service is to be performed primarily in the participating provinces. The supply of the service is considered to be made in the participating province in which the greatest proportion of the Canadian element is to be performed; or •   the place of negotiation for the supply is located outside Canada, if all or substantially all of the service is to be performed in Canada, and it is to be performed primarily in the participating provinces, the supply is considered to be made in the participating province in which the greatest proportion of the services to be performed in the participating provinces are to be performed. ... Legislative References: ETA: 123(1); 142; 144.1; 165(1) & (2); IX/V/1; IX/I/1; NCS Subject Code(s): 11875-1 Policy paper: P-077R- SINGLE MULTIPLE SUPPLIES P-078R- MEANING OF THE PHRASE "DELIVERED OR MADE AVAILABLE IN (OR OUTSIDE) CANADA TO THE RECIPIENT" P-159R- MEANING OF THE PHRASE "REASONABLY REGARDED AS INCIDENTAL" P-160- MEANING OF THE PHRASE "WHERE A PARTICULAR PROPERTY OR SERVICE IS SUPPLIED TOGETHER WITH ANY OTHER PROPERTY OR SERVICE" c.c.: P. ...

The following information was provided in your letter and telephone messages: XXXXX  is registered for GST/HST purposes XXXXX •   XXXXX  is engaged in the commercial activity of providing access to a software application called XXXXX through the internet for a fee ranging from $XXXXX  The software application is stored on servers located in XXXXX a and is accessed through the website "XXXXX. ... The rate charged is dependent upon the sample exam the client requests to access. •   The client must pay the access fee prior to receiving access to the desired exam. ... Once the credit card charge has been accepted by the appropriate clearing agency XXXXX issues a password to the client which allows access to the requested exam. •   While some of XXXXX clients are residents of Canada, a significant number are non-residents for purposes of the Excise Tax Act (the "Act"). ...