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2 April 1996 GST/HST Interpretation 11645-1[3]- Importation of Unedited CRA Tags ETA 169(1); ETA 212                                                                         File #: 11645-1 (gp)                                                                         ss. 169(1), 212 XXXXX April 2, 1996 Dear Mr. ... The following information was provided in your memorandum and in a subsequent telephone conversation with Gwen Preston of my staff: •   XXXXX[.] •   XXXXX receives an order for a XXXXX from a XXXXX dealer in Canada and installs the kit into a XXXXX[.] •   When the van conversion is complete, XXXXX ships the van to the dealer and invoices the dealer for the kit and the installation. •   At time of importation, XXXXX pays the duties and GST on the van, including the value of the kit with the entry for the van. ... Jones Director General Applications Division GST Rulings and Interpretations Directorate Policy and Legislation Branch GAD # 2823 (GEN) c.c.: R. ...

>>Researches insurance products. • Presents product offerings. • Provides Client with a copy of the disclosure material (an information folder), including the contract provisions. • Explains contract terms. • Answers Client's questions. • Assists Client in completing application for insurance. • Reviews application and ensures it is complete, and forwards the completed application to the insurer. • Ensures that all requirements are satisfied so that the Client can obtain the insurance. • In some cases, collects the first premium and forwards to insurer with application. ... The functions performed by the Advisor prior to the issuance of policy: • Same as Example 1. • Works with Client to develop an employee benefit plan, which includes explaining the various options • Solicits proposals from a number of insurers for the particular insurance product. • Assists in explaining the insurance policy to the employees as required. ... >>Conducts Client needs assessment. • Identifies opportunities for insurance product sales, including initial screening for Client insurability and eligibility for certain products. • Researches insurance products. • Presents product offerings. • Provides Client with a copy of the disclosure material (an information folder) including the contract provisions. • Explains contract terms. • Answers Client's questions. • Assists Client in completing application for insurance. • Reviews application and ensures it is complete, and forwards the completed application to the insurer. • Ensures that all requirements are satisfied so that the Client can obtain the insurance. ...

Such features and adaptations may include: •   lowered floor; •   extended side sliding door for increased entry height; •   removable front seats; •   modified suspensions; •   swing away manual ramp; •   remote control for door and ramp; •   fold out power ramp; and •   hand controls. ...

Scenario 1 •   XXXXX is resident in XXXXX and is registered for GST/HST purposes XXXXX[.] •   XXXXX creates both doorway /search pages and unique Web sites pertaining to a given product or service XXXXX[.] •   Dar-Ray submits the pages or Web sites to various search engines in hopes of attracting potential customers. •   XXXXX receives a commission XXXXX if someone goes through its search pages or Web site to access the website XXXXX or XXXXX. •   XXXXX receives a commission only if a person XXXXX redirects uses a service or purchases a product from the other Web sites. •   XXXXX[.] Scenario 2 •   Using the same marketing techniques as described in Scenario 1, Web site owners offer to pay a set rate XXXXX for people XXXXX redirects from XXXXX or search pages to it's client's Web site. •   In order to receive the set rate, the person redirected from XXXXX Web site must actually enter the XXXXX Web site(s) beyond the welcome pages. •   XXXXX[.] •   XXXXX[.] ... Also enclosed is GST/HST Memoranda Series Section 4.5.3, Exports — Services and Intellectual Property. ...

. / 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. ... We understand the following background: • [...] (the "Company") is a Canadian, commercial, [...] corporation registered for the GST. • The Company entered into an agreement with a non-resident service supplier for the refurbishment of equipment that is used in the Company's commercial activities. • The non-resident service supplier is registered for the GST. • The Company's equipment is transported to the registered, non-resident service supplier's location outside Canada where the refurbishment service is performed. • Upon completion of the refurbishment service, the Company's equipment is returned to Canada by the registered, non-resident service supplier who acts as the importer of record and is responsible for paying the assessed import duties and other taxes, including the GST. ... • If the registered, non-resident service supplier is not entitled to an ITC in respect of the GST paid, is the Company able to use section 180 of the ETA? ...

3 February 1997 GST/HST Interpretation 11640-4[2]- Export of Tangible Personal Property Unedited CRA Tags ETA Sch VI, Part V, 12                                                                         File #: 11640-4(glr)                                                                         February 3, 1997 Thank you for your E-mail message of January 21, 1997, on the above-referenced subject. ...

XXXXX clients are also offered the following options: •   additional on-line storage space; •   more data storage (off-line); •   monthly or daily back-up services; •   e-mail enhancements, such as virus scanning and SPAM filtering; •   domain management; •   statistical analysis tools such as statistical tracking; and •   added bandwidth. ...

Based on your letter and the documentation, we understand that: 1. […] (the Corporation) is proposing to set up a subsidiary, […] (the Agency), which would be regulated and licensed provincially as an insurance agent. 2. The Agency would enter into a proposed […] Agreement (the Proposed Agreement) with an insurance company that would be authorized under the laws of Canada to carry on an insurance business. […]. 3. […][Terms of the agreement]. 4. ... The Proposed Agreement provides that, in consideration for the fulfilment of the Agency’s responsibilities […], fees will be paid in accordance with each […] exhibit. […]. ...

The price is XXXXX in 1994 dollars to be paid in a series of payments starting with an advance before the agreement is signed followed by payments: •   on submission of certified design drawings •   on completion of successful pre-trip system check •   on mobilization of the schnabel and shipping saddles on XXXXX property •   on delivery of each of [(]XXXXX RSGs) 5. ... XXXXX shall provide all railway cars and arrange for rail transportation by XXXXX of the schnabel and RSGs including being responsible for •   obtaining all railway clearances, permission and approval for the transport by rail of the schnabel, •   satisfying all conditions imposed by any railway company, •   paying all railway freight charges including line haul charges and special train charges, •   establishing the route, and •   any modification or improvement to track or the right of way, all at XXXXX own expense; 7. ... The insurance taken out by XXXXX is to include: •   general liability insurance for damage because of bodily injury including death of any person caused by the schnabel; •   property damage insurance for direct physical loss up to full replacement cost of the schnabel; •   workers' compensation or similar XXXXX insurance; •   contractor's equipment insurance to cover equipment used in performing XXXXX responsibilities; •   automobile third party liability insurance to cover all motor vehicles owned, hired or used by XXXXX for all claims for bodily injury including property damage and passenger hazard with limits of not less than XXXXX per occurrence. 9. ...

Based on the information […] we received […], we understand the following: 1. ... The Bill of Lading lists the shipper/exporter as […] (“Canco”) and the consignee as […] (“Nonresco”). 4. ... The […] “tax deposit refund” […] is an amount agreed to by the parties to the transaction, Nonresco[’s] […] best avenue for recovering this deposit is by taking the matter up directly with Canco. […]. ...