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31 August 1998 GST/HST Interpretation HQR0000454- GST RULING Eligibility for Charity Rebate Unedited CRA Tags ETA 259                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0000454 XXXXX August 31, 1998 Subject: GST RULING Eligibility for Charity Rebate This is in reply to the letter of September 16, 1996 from XXXXX to XXXXX Tax Services Office, wherein he requested a GST application ruling on whether XXXXX (the Society) is eligible for a rebate pursuant to section 259 of the Excise Tax Act (ETA). ... Its official objects read (in part): i) to acquire title to land from XXXXX and to construct and operate thereon, housing facilities for the aged [...] ii) to provide relief and assistance for the aged, in and around XXXXX by building and operating a housing facility for the aged and in such facility, providing such activities, amenities, assistance, including financial, care comfort, companionship, facilities, services and support to the aged residents of the facility [...] 3. ...

12 May 1998 GST/HST Ruling HQ0000746- Application of the GST/HST to the Activities of a University With Respect to the Supply of Cattle Unedited CRA Tags ETA 123(1) university; ETA Sch V, Part VI, 10                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, Ontario K1A 0L5  XXXXX  XXXXX  XXXXX May 12, 1998  XXXXX                Case: 0000746 Subject: GST/HST APPLICATION RULING XXXXX Dear XXXXX This is in response to your letter (with attachments) of April 14, 1997, to the XXXXX Tax Services Office (TSO) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the activities of the XXXXX. ... Pursuant to XXXXX of XXXXX "... upon dissolution...any property remaining after the satisfaction of all debts and other liabilities...shall be conveyed to the XXXXX for the benefit of the XXXXX and the XXXXX 3. Pursuant to XXXXX "... The Corporation shall not carry on any activities other than: i) to initiate, undertake, coordinate and promote research, experiments, and education related to the housing, reproduction, nutrition, welfare, rearing, health, management utilization, and marketing of beef and related products and by-products; ii) to undertake programs of developing and disseminating production technology and management information arising from the Corporation's own research project or research and experiments carried on by other beef producers and research institutions, all in a manner consistent with servicing the interests of the beef industry in XXXXX and Canada; iii) any activities or undertakings which are incidental to and necessary for the accomplishment of any of the foregoing, including, without limitation, the leasing, purchasing and or construction of facilities and equipment necessary to rear, produce and market beef; iv) those activities which in the opinion of the board of directors of the Corporation, are related to or incidental to or which will assist the Corporation in the attainment of the foregoing. ...

3 March 1999 GST/HST Interpretation HQR0001306- Application of the GST/HST to the Sale of Precious Metals Unedited CRA Tags ETA 141.01; ETA 149(1); ETA 186(2); ETA 186(3); ETA 123(1) exclusive; ETA 123(1) money; ETA 123(1) property TO: XXXXX XXXXX XXXXX FROM: Kirk Moore, A/Technical Officer Corporate Reorganizations GST/HST Rulings & Interpretations Subject: XXXXX This is in response to a memo from XXXXX concerning certain ITC claims made by XXXXX relating to the takeover of XXXXX, formerly XXXXX, has claimed ITCs in respect of certain costs (the "Costs") incurred by XXXXX in taking over XXXXX XXXXX[.] ... XXXXX [.] Thus, the period referred to in subsection 186(2) begins some time before XXXXX XXXXX when XXXXX first became the recipient of supplies of property or services relating to the acquisition or proposed acquisition of all or substantially of the issued and outstanding shares of XXXXX stock having full voting rights under all circumstances. ... Legislative References: s. 141.01, s. 149(1), s. 186(2) & (3), s. 123(1) Def'n "exclusive", "money", "property" NCS Subject Code(s): 11585-13, 11585-11 ...

XXXXX of the Articles of Incorporation state that "... (a) the shares shall entitle their respective holders to participate pari passo in any surplus or profits.... ... Ruling Response Based on the facts set out above, we rule that in accordance with section 259 of the ETA, as a qualifying non-profit organization, ABC Inc. is entitled to a PSB rebate equal to 50 % of its non-creditable tax charged in respect of the fiscal year ending December 31, 2000. ... Explanation Pursuant to subsection 123(1) of the ETA, a "non-profit organization" is: "... a person (other than a...charity... or a government) that was organized and is operated solely for a purpose other than profit, no part of the income of which is payable to, or otherwise available for the personal benefit of, any proprietor, member or shareholder thereof.... ...

27 March 2001 GST/HST Interpretation 33592- Sale of Residential Complexes Unedited CRA Tags ETA 123(1) builder; ETA 123(1) multiple unit residential complex; ETA 123(1) residential complex; ETA 123(1) residential unit; ETA 123(1) sale; ETA 123(1) single unit residential complex; ETA 123(1) substantial renovation; ETA 136(2); ETA 191; ETA 259(1) municipality; ETA 336(1); ETA Sch V, Part I Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXXAttention: XXXXX XXXXX File # 11894-7XXXXX XXXXX XXXXXCase 33592March 27, 2001 Subject: GST/HST INTERPRETATION Sale of Residential Complexes Dear XXXXX: Thank you for your letter of November 17, 2000 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the proposed transfers of real property described below. ... Section 191 ensures that GST/HST applies to newly constructed or substantially renovated premises once they are rented out or otherwise occupied as places of residence before being sold (Subsection 123(1) of the ETA defines "sale" in respect of real property as including "... any transfer of the ownership of the property and a transfer of the possession of the property under an agreement to transfer ownership of the property".), since the subsequent sales of those premises will generally be exempt of GST/HST, as used housing. ... Cahill Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate Legislative References: ETA ss 123(1), ss 136(2), s 191, ss 336(1), Pt I Sch V References: Ernst & Young Goods and Services Tax the Complete Guide 2000 (8th) Edition Volume 3 Consolidated Explanatory Notes Section 19.1 Real Property and the GST/HST GST/HST Memoranda Series para 105 Section 19.2.1 Residential Real Property- Sales GST/HST Memoranda Series para 8 Section 19.4.1 Commercial Real Property- Sales and Rentals GST/HST Memoranda Series para 9 NCS Subject Code(s): R-11894-7 ...

Interpretation Requested The scenario that you described in your letter involves a corporate entity that operates a private clinic to provide the following services to individuals using specialized equipment that it owns: •   An XXXXX that uses laser technology to measure the ocular axis length, corneal radius and anterior chamber depth of the eye. These calculations would assist an eye surgeon in determining the strength and size of an intra-ocular lens required for implantation after cataract extractions. •   A XXXXX that is used to map the optic nerves at the back of the eye for assisting a physician or surgeon in the early detection of glaucoma. ... After the ER physician receives his fees from the provincial health insurance plan, he forwards XXXXX % to the ophthalmologist as a referral fee. ...

The "commission" is equal to XXXXX % of the retail sale price of each product sold, excluding shipping charges. 9. XXXXX forwards to the vendor any payment received in respect of the sale of the products made through its Web site less the XXXXX % amount it retains. 10. ... Under the XXXXX Agreement, XXXXX is supplying an advertising service to the vendor; 2. the supply of the advertising service is made in Canada and is subject to the GST at a rate of 7% when the service is provided to a vendor who is resident in Canada; 3. when the supply of the advertising service is made to a non-resident person, that supply is zero-rated (i.e., taxed at a rate of 0%) pursuant to section 7 or section 8 of Part V of Schedule VI to the Excise Tax Act (ETA); and 4. the XXXXX % amount charged by XXXXX to a vendor is additional consideration in respect of the advertising service and will have the same tax treatment as described above. ...

. / 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. GST/HST Rulings Directorate Place de Ville, Tower A, 5th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 244638 Dear [Client]: Subject: GST/HST RULING Acting as an Intermediary Between a Merchant and an Acquirer under a Payment Card Network Thank you for your letter of [mm/dd/yyyy], in which you requested a ruling on behalf of […] (the “Company”), with respect to the application of the goods and services tax/harmonized sales tax (GST/HST) to the services supplied by the Company. ... STATEMENT OF FACTS For the purposes of your ruling request, you provided us with electronic copies of the following documents: Merchant Agreement between […][ACo] and a retailer (herein, the “Sample Merchant Agreement”) […] Agreement between the Company and [ACo] ([…][Agreement X]) Based on the information contained in your letter, the above documents and our telephone conversation of [mm/dd/yyyy], we understand the following: 1. ...

. / 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. ... Subsection 188.2(5) provides an exclusion to subsection 188.2(2) to (4) to the extent that the mining activity is performed by a particular person for another person if (a) the identity of the other person is known to the particular person; (b) where the mining activity is in respect of a mining group that includes the particular person, the other person is not a mining group operator in respect of the mining group; and (c) where the other person is a non-resident person and is not dealing at arm’s length with the particular person, each property or service — being property or a service that is received by the other person from the particular person as a consequence of the performance of the mining activity — is supplied, or is used or consumed in the course of making a supply, by the other person to one or more persons each of which (i) is a person whose identity is known to the other person, (ii) deals at arm’s length with the other person, and (iii) is not a mining group operator in respect of a mining group that includes the other person if the mining activity is in respect of that mining group.” ...

. / 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. GST/HST Rulings Directorate 5th floor, Tower A, Place de Ville 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 247708 Business Number: […] Dear [Client]: Subject: GST/HST interpretation- […][the Company] and the purpose-built rental housing (PBRH) rebate Thank you for your correspondence of May 21, 2024, concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to […][the Company] and their eligibility to claim the PBRH rebate. ... As discussed […], we are issuing an interpretation for this ruling request, which is a general explanation of the applicable provisions and how the legislation will apply. ...