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Warren, Rulings Officer, Real Property Unit, GST R & I, letter to XXXXX XXXXX (HQR0001063, October 2, 1998)D. Hooley, Senior Technical Analyst, Real Property Unit, Excise & GST/HST Rulings, Email message to C. ...

Section 1 of Part I of Schedule IX to the Act 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... ... A copy of Policy Statement P-222 Acceptable Exchange Rate Sources for Converting the Value of Consideration Expressed in Foreign Currency to a Value in Canadian Currency for Purposes of Section 159 of the Excise Tax Act " is also enclosed for your reference. ...

. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. ... Each Concurrent Lease will commence on the lease date set out on the Asset Lease and ends "... ...

The Head Lease has the following terms relevant to the issues of this interpretation: (a) The XXXXX Assets will remain property of, and title to the XXXXX Assets will remain in, the Utility; XXXXX (b) The City shall retain possession and quiet enjoyment of the XXXXX Assets until the end of the lease term; XXXXX (c) The Head Lease calls for a lease term of XXXXX years; XXXXX (d) The Utility has the right of early termination after XXXXX years of the lease term has lapsed; XXXXX (e) The City agrees to pay an annual rent for the XXXXX Assets and the parties acknowledge that the GST is applicable to the rent payments; XXXXX (f) The City is granted the right to prepay XXXXX % of the total annual rent for the lease term at the present value of the annual rent over the lease term using a discount rate of XXXXX % (note, this right was exercised by the City); XXXXX (g) The Utility acknowledges and agrees that the City shall be permitted to assign or sublet the XXXXX Assets to another party to operate as contemplated in XXXXX (h) Where the City assigns or sublets the Head Lease or the XXXXX Assets, such assignment or subletting shall not merge with the Head Lease; XXXXX and (i) The "lessee[City] agrees that the XXXXX Assets remain the property of the Utility notwithstanding the manner in which or the degree to which the same may be attached or affixed to realty"; XXXXX 3) The City and the Utility entered into the Sublease dated XXXXX (Sublease) whereby the City, as lessor, subleased the XXXXX Assets to the Utility, as lessee. ...

However, as the terminology and rules related to the ownership of the copyright may differ between the U.S. and Canada, Can Co. has established a XXXXX % owned subsidiary based in XXXXX to serve its U.S. clients. ... In accordance with this provision, a supply of IPP is considered to be made in a province if the place of negotiation ("place of negotiation" of a supply refers to "... 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, or to which that individual ordinarily reports, in the performance of the individual's duties in relation to the activities of the supplier in the course of which the supply is made... ...

Section 1 of Part I of Schedule IX to the ETA defines the "place of negotiation" 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, or to which that individual ordinarily reports, in the performance of the individual's duties in relation to the activities of the supplier in the course of which the supply is made... ... Yours truly, Anne Kratz Electronic Commerce Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate ...

In that regard, policy paper P-077R, " Single and Multiple Supplies ", provides assistance. ...

The purchase price is either: •   as stipulated in advance in a schedule in the strata lot plan; or •   if not so stipulated, based on the fair market value of the leaseholder's interest "evaluated as if the lease did not expire". ... More precisely, this subparagraph (i) requires that the supplier "give possession (...) under a lease". ... Paragraph 254(2)(e) of the Act requires that, "... ownership of the... unit is transferred to the particular individual after the construction or substantial renovation thereof is substantially completed... ...

. / 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. ...

1 April 1998 GST/HST Interpretation HQR0000904- Sale of Lots Created by Consolidation and Subdivision Unedited CRA Tags ETA Sch V, Part I, 9(2)(c)                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue  XXXXX                                                                                Vanier, Ontario  XXXXX                                                                                K1A 0L5 XXXXX Case: HQR0000904 XXXXX April 1, 1998 Subject: GST/HST INTERPRETATION Sale of Lots Created by Consolidation and Subdivision Dear Sir: This letter is in reply to your telephone enquiry concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the sale of lots created by a plan of subdivision when the land subdivided was previously owned by the vendor in two or more contiguous parts. ...