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. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Yours truly, Dave Caron Manager, Aboriginal Affairs Unit Public Services Bodies & Governments Division Excise and GST/HST Rulings Directorate UNCLASSIFIED ...

7 June 1995 GST/HST Interpretation 11755-20[2]- Sale of Aircraft with Modifications Unedited CRA Tags ETA 153(2)                                                                         File no.: 11755-20(SB); 11990-1  XXXXX Technical Services Group Taxes Services XXXXX                                                     June 7, 1995 This is in reply to your memorandum of March 3, 1995 regarding the above mentioned subject. ... Facts We have listed hereafter the provisions of the agreement that may be useful in determining whether the aircraft and the modifications are all part of a single supply or constitute separate supplies AIRCRAFT PURCHASE AGREEMENT / DECEMBER 28, 1988 Definitions: Maintenance and Modification Program The maintenance and modifications defined by XXXXX and agreed by XXXXX as set forth in Paragraph III of Exhibit A, which maintenance and modifications shall be performed by XXXXX prior to Delivery to XXXXX Section 2.01: Purchase of the Aircraft  XXXXX agrees to sell to XXXXX and XXXXX agrees to purchase from XXXXX the Aircraft, in accordance with the terms and conditions set forth in this Agreement. ...

11 May 1995 GST/HST Interpretation 11935-2[1]- The Tax Status Under the GST of Fees Paid by Parents in Order That Their Children May Attend a Hockey Camp Unedited CRA Tags ETA Sch V, Part IV, 1                                                                         Doc. ... The ETA does not provide direction as to what constitutes a "primary purpose" so we must look to the commonly accepted meaning of "primary" which is generally described as: " of the first importance, principal, chief, main, or of the first rank". ...

Subsection 123(1) of the ETA defines "trailer park" of a person as "... a piece of land that is owned by or leased to the person and that is exclusively composed of  (a) one or more sites each of which is, or is intended to be, supplied by the person by way of lease, licence or similar arrangement to the owner, lessee or person in occupation or possession of a mobile home, or a travel trailer, motor home or similar vehicle or trailer, situated or to be situated on the site, and (b) other land that is reasonably necessary for (i) the use and enjoyment of the sites by individuals residing in or occupying mobile homes, or travel trailers, motor homes or similar vehicles or trailers, situated or to be situated on those sites, or (ii) the purpose of engaging in the business of supplying the sites by way of lease, licence or similar arrangement;". ... Subsection 123(1) defines the term "residential trailer park" as "... the land that is included in a trailer park of the person or, where the person has two or more trailer parks that are immediately contiguous to each other, the land that is included in those contiguous trailer parks, and any buildings, fixtures and other appurtenances to the land that are reasonably necessary for (a) the use and enjoyment of sites in the trailer parks by individuals residing in or occupying mobile homes, or travel trailers, motor homes or similar vehicles or trailers, situated or to be situated on those sites, or (b) the purpose of engaging in the business of supplying those sites by way of lease, licence or similar arrangement, but does not include such land and appurtenances or any part of them unless the land encompasses at least two sites and all or substantially all of the sites in the trailer parks (c) are supplied, or are intended to be supplied, by way of lease, licence or similar arrangement for a period of at least (i) one month, in the case of a mobile home or other residential unit, and (ii) twelve months, in the case of a travel trailer, motor home or similar vehicle or trailer that is not a residential unit, and if the sites were occupied by mobile homes, would be suitable for use by individuals as places of residence throughout the year;". ...

In summary, the scrap metal dealer can claim an NITC on the purchase in XXXXX of aluminum beer cans only if the following conditions are met: •   the first three conditions for the application of subsection 176(1) of the ETA listed above are satisfied; and •   one of the exceptions listed in subsection 226(5) of the ETA applies so that subsection 226(4) of the ETA does not apply to the transaction. ...

17 July 1998 GST/HST Interpretation HQR0000921- GST/HST New Housing Rebates Unedited CRA Tags ETA 123(1) residential condominium unit; ETA 254; ETA 262; INTACT 33(2)                                                                         GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario XXXXX                                                                                 K1A 0L5 XXXXX File 11870-14-25 XXXXX                 Case: HQR0000921 XXXXX July 17, 1998                                                                         Your File: XXXXX Dear XXXXX We are writing in response to a memo received from XXXXX of your office, dated October 22, 1997 respecting multiple GST/HST new housing rebate applications for side by side residential condominium units (RCU) connected by way of a sliding door and respecting the primary residence requirement. ...

VI, partie IV, 1.1                                                                         Direction des décisions et de l'interprétation de la TPS/TVH 25, avenue McArthur, 9ème étage, tour "C"  XXXXX                                                                                Vanier (Ontario)  XXXXX                                                                                K1A 0L5  XXXXX Codification-sujet: 11845-2(rl)  XXXXX                Numéro de dossier: HQR0000778                                                                         le 27 mai 1998  XXXXX La présente fait suite à votre lettre du 23 mars 1998 adressé à Mme Susan Mailer, gestionnaire de l'unité des Industries. ...

The payment of the monthly fees entitles residents, among other things, to use the community recreational facilities, including a $ XXXXX recreation centre and tennis courts. ... However, as per Policy Statement P165 entitled "Fair Market Value (FMV) For Purposes of the Excise Tax Act ", the Department's position is that FMV represents the highest price, expressed in terms of money or money's worth, obtainable in an open and unrestricted market between knowledgeable, informed and prudent parties acting at arm's length, neither party being under any compulsion to transact. ...

2 March 1998 GST/HST Interpretation HQR0000567- Applications of the GST/HST to the Services of a Low Emissions Vehicle Program Unedited CRA Tags ETA 123(1) non-profit organization; ETA 133; ETA 135; ETA 141.01; ETA 153(1); ETA 153(3); ETA 165(1); ETA 181.1; ETA Sch V, Part VI, 10                                                                         Directorate Place Vanier, Tower C, 9th Floor 25 McArthur Avenue Ottawa ON XXXXX                                                                                 K1A 0L5 XXXXX Case: HQR0000567 XXXXX March 2, 1998 XXXXX Dear XXXXX Thank you for your letter of February 14, 1997, with attachments, concerning the application of the Goods and Services Tax (GST)Harmonized Sales Tax (HST) to the transactions being undertaken by the XXXXX ("the Program"). ... The Program does not have, to any significant extent, directors, officers, or employees that are common with XXXXX For instance, the Program has its own Steering Committee made up of: · XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX 23. ...

. •   "Delivered" refers to those situations where delivery of the TPP under the applicable law of the sale of goods is effected by actual delivery. In other words, delivery of the TPP may be effected by a transfer of the actual physical custody of the TPP from the buyer to the seller. •   "Made available" refers to those situations where delivery of the TPP under the applicable law of the sale of goods is effected by constructive delivery (i.e., actual physical possession of the TPP is not transferred to the recipient of the supply). ...