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The following information was presented in your letter: •   Your client ("the Company") is a company located in the United States (US) and is not registered for purposes of the GST/HST. •   The company will be selling digitized music files over the Internet to consumers, resident in Canada. •   The purchaser of the music files will download a digitized data file that is a music track. ... The purchaser will only receive the right to download and use the digitized data file. •   The purchaser will only be able to play this music for personal use and will not be permitted to resell it or use it for any commercial application. •   All electronic files will be downloaded from a server site in the US. ... The factors that the CCRA will consider, both in a traditional and electronic commerce environment, in determining whether a non-resident person is carrying on business in Canada in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made; •   the place from which transactions are solicited; •   the location of an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ...

Une « voiture de tourisme » est défini au paragraphe 123(1) comme une voiture de tourisme ou une voiture de tourisme zéro émission, au sens du paragraphe 248(1) de la [LIR]. Selon ce paragraphe, une « voiture de tourisme » désigne généralement une « automobile » acquise après le 17 juin 1987. ... Bien que la prestation de services de covoiturage commerciaux soit une « entreprise de taxi » aux fins de la TPS/TVH, il n'était pas clair si un véhicule utilisé pour fournir de tels services était considéré comme un « taxi » dans le contexte de la définition d'automobile dans la LIR. ...

The XXXXX package includes the items delineated in XXXXX to the Tenancy Agreement (attached as Appendix 1 of your submission) and in the "XXXXX Information Package" (attached as Appendix 2), namely: •   a specific suite and the property and services indicated in Fact 6, •   call-bell monitoring (i.e., a personal emergency response system), •   an on-site nurse manager and at least one nurse on duty 24 hours per day to respond to emergency situations, •   activity programs tailored to the needs of the Residents, •   weekly housekeeping services including a change of bed linens and towels, and •   one dinner served daily that takes into consideration special dietary needs of the Residents. 8. The XXXXX package includes the items delineated in XXXXX to the Tenancy Agreement (attached as Appendix 1 of your submission) and in the "XXXXX Information Package" (attached as Appendix 2), namely: •   a specific suite and the property and services indicated in Fact 6, •   call-bell monitoring, •   an on-site nurse manager and at least one nurse on duty 24 hours per day to respond to emergency situations, •   activity programs tailored to the needs of the Residents, •   administering medication to residents on an as-needed basis, •   daily light housekeeping and weekly housekeeping services including a change of bed linens and towels, •   assistance with bathing once a week, and •   three meals daily (that take into consideration special dietary needs of the Residents) and meals delivered to a Resident's room when authorized by the nursing manager. 9. ... These services are described in XXXXX to the "XXXXX Information Package" (attached as Appendix 2 of your submission) as follows: •   assistance with bath or extra bath- $XXXXX/bath, •   personal laundry- $XXXXX/load, •   more frequent or daily housekeeping- $XXXXX/month, •   one extra full clean of a suite per week- $XXXXX/month, •   extra assistance for dressing or other personal services- $XXXXX/hour, •   escort services to and from the dining room- $XXXXX/month, •   extra breakfast plan- $XXXXX/month, •   extra lunch plan- $XXXXX/month, and •   extra breakfast and lunch plan- $XXXXX/month. ...

We understand that: • [...] (the "Company") is a GST/HST registered company located in [...] ... The company provides [...] services in [...] for companies importing into Canada. • The Company's clients include GST/HST registered non-resident importers that do not have a physical presence in Canada. ... Yours truly, Carolle Mercier Unité des questions frontalières / Border Issues Unit Division des opérations générales et des questions frontalières / General Operations & Border Issues Division Direction de l'accise et des décisions de la TPS/TVH / Excise and GST/HST Rulings Directorate UNCLASSIFIED ...

In your letter of [mm/dd/yyyy], you provided a further detailed explanation […] of the responsibilities, role and functions of [the Dealer] in the industry context, an example, a Sample Referral Agreement and enclosed the following additional documentation: * Subscription Agreement between […][ACo] and Investor (the [A] Agreement); * Subscription Agreement between […][BCo], […][CCo] and Investor (the [B] Agreement); * […]. You also referred us to […] copy of the publicly-filed agency agreement between [BCo] and [CCo], […], […] and […] (collectively called the Agents) ([C] Agency Agreement) referred to in the above-noted [B] Agreement. ... [A] Agreement 13. […] [Under the] [A] Agreement […] between [ACo] (the Corporation) and an investor (the Investor)[,] […] the Investor may subscribe to purchase a specific number of shares or warrants of the Corporation. ...

14 March 1995 GST/HST Interpretation 11995-1[1]- The Storage of Empty Containers Which Have Been Repositioned Under the                                                                         signed 950314                                                                         File: 11995-1(DRM)                                                                         Doc: 100 XXXXX March 14, 1995 Subject: The storage of empty containers which have been repositioned under the XXXXX I refer to your letter of November 17, 1994, to Mr. ... Venne Director Tax Policy- Special Sectors GST Policy & Legislation c.c.: A D'Abramo c.c.:      A. ...

10 October 1995 GST/HST Interpretation 11925-1[3]- Status Under the GST of Supplies Made by the Unedited CRA Tags ETA 123(1) business                                                                         File # 11925-1(EB)                                                                         Doc.# 1200                                                                         Leg. ... Draft policy statement 167 entitled " Meaning of the First Part of the Definition of Business " sets out certain criteria that may be useful in establishing whether an activity will constitute a business. ... This conclusion is based on the following facts: •   the XXXXX does not have a fixed address or permanent premises housing its operations; •   the XXXXX does not have a telephone listing- persons wishing to contact the organization must contact a member of the XXXXX[;] •   the XXXXX does not advertise to the public how it may be contacted- the individuals who are the focus of this organization's activities (i.e., those involved in the XXXXX industry or related businesses) are aware of who the organization's officers are and how to contact them; •   there is no full or part time staff- the XXXXX activities are carried on by its XXXXX[;] •   at the annual General Meeting of the XXXXX the members of the XXXXX are appointed by the XXXXX of the XXXXX[;] •   these members with the exception of the XXXXX and the XXXXX, are automatically terminated at the subsequent annual general meeting; •   there is no ongoing office activity carried on at a particular location; •   there are no specific day to day activities- members of the XXXXXX carry on activities on behalf of the XXXXX in their own office locations as required; •   the XXXXX does not advertise or carry on promotional activities to attract interest in its activities- invitations to the golf tournament are highly prized as only so many are issued. ...

. / 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. ... [STATEMENT OF FACTS] Based on the […] information provided […], we understand the following: * The Parent is the parent corporation of a complex structure of entities, […]. The Parent owns units of […][Trusts] […]. * […][Information about specific transactions] * […][Specific information about the organizational structure] * We understand that […][the supply of real property to other entities] is a commercial activity for GST/HST purposes. * The […][argument has been made] that [the Parent] provides management services to related entities, and has provided sample invoices which indicate that it provides management services to […][X], however, we have not been provided with any agreements for management services. ...

Generally, medical reports supplied to third parties that are viewed as being ancillary to an exempt supply of a health care service are those that relate to an individual's present health status for: •   insurance medical examinations not relating to claims or settlements; •   employment examinations; •   pre-placement examinations; •   immigration examinations; •   executive medical examinations; and •   return-to-work examinations. ... Since these professional opinions are not prepared as a result of rendering a health care service to an individual, the following medical reports and opinions are outside the scope of the exempting provisions in Part II of Schedule V to the ETA and are therefore taxable: •   opinions provided by health care practitioners under contract with insurance companies and other parties; •   reports/opinions prepared as a result of independent insurance medical examinations/assessments that relate to claims and settlements; and •   medico-legal reports. ...

Section [#] of the LPA states that the business of the LP is to acquire real property described in […] the LPA and […]: namely: The lands municipally known as […], having an area of approximately [...] shown as […] on the draft reference plan dated [mm/dd/yyy] prepared by […]. 4. ... The purpose of the [agreement 4] is […](Project Bonus) […]. […]. 22. Section [#] of the [agreement 4] sets out […]Project Bonus […]. 23. ... LP1 claimed ITCs of $[…] on its [mm/yyyy] GST/HST return, which included $[…] from the supplier of accounting services. 33. […]. 34. […]. 35. ...