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XXXXX: • XXXXX. • XXXXX. 22. The web site for the Products (www. theprobar.com) was reviewed. ... A description of those not included in bullet 21 above is as follows: • XXXXX. • XXXXX. 23. There are XXXXX different XXXXX product types listed on the web site as follows: • XXXXX. • XXXXX. 24. ...

. / 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. ... The Class B Limited Partner’s only activity is its investment in the Partnership; it is not a member of the Partnership Advisory Committee. 4) Pursuant to section […] of the Partnership Agreement, in addition to the distributions to be made pursuant to sections […], […] and […] of the Partnership Agreement when a general partner resigns or is removed, or the Partnership is sold or dissolved, the Partnership will, subject to section […], make a distribution to the holders of Class B Units and Class C Units (the “Priority Distribution”) in proportion to their ownership of Class B Units and Class C Units equal to an undisclosed specified percentage per annum of an undisclosed factor. 5) Pursuant to section […] of the Partnership Agreement, the general partner is required to make distributions to the partners from time to time- that is, essentially all sums received from eligible investments, net of: the payment or reimbursement of the partnership expenses, which includes the payment of management fees, […] and other types of fees pursuant to section […], and the payment of the Priority Distribution. 6) Section […] of the Partnership Agreement provides that amounts distributed shall be distributed to the partners as follows: * first, to the holders of Class B Units and Class C Units in proportion to their ownership of Class B Units and Class C Units, until such time as the holders of Class B Units and Class C Units have received all due and unpaid Priority Distributions; * as to the balance: […]% to the general partner and […]% to the limited partners in proportion to their ownership of Class A Units. ... You state that the management fee payable to the Manager under the Management Agreement and referenced in section […] of the Partnership Agreement is subject to the GST/HST. ...

The Company is a Canadian corporation that is registered for GST/HST purposes. […]. 2. ... The Product packaging consists of a ridged clear plastic container measuring approximately [#]” x [#]” x [#]” deep with two separate compartments. ... The package size is [#] grams […]. RULING REQUESTED You would like to know whether the supply of the Product is zero-rated under section 1 of Part III of Schedule VI. ...

SLPs work in a variety of health and educational settings, such as: •   Hospitals, •   Public health units, •   Community health centres, •   Schools, •   Children's treatment centres, •   Community Care Access Centres, •   Private practice, •   Preschool settings and daycare centres, •   Resource centres, •   Facilities for developmentally or physically challenged individuals, and •   Nursing homes and long-term care facilities. You indicated that the duties of an SLP include the following: •   Administering tests and examinations and observing patients to diagnose and evaluate speech, voice resonance, language, cognitive linguistic and swallowing disorders. •   Planning and implementing remedial programs to correct speech, language and voice disorders. •   Establishing group and personalized care plans working as a member of an interdisciplinary team. •   Conducting research on speech and other communication disorders and on the development and design of diagnostic procedures and devices. •   Instructing students and other personnel. ... Yours truly, Susan Eastman Municipalities and Health Care Services Unit Public Service Bodies and Governments Division 2004/11/02 — RITS 50061 — Services Supplied by XXXXX [Instructors and Therapists] ...

XXXXX (Product A) •   Product A is a non-carbonated liquid vitamin-mineral concentrate. •   Product A contains no fruit, fruit juice or fruit flavouring. •   Product A contains the Non-Medicinal Ingredients: XXXXX XXXXX. •   According to the Product A label, the directions for use are as follows: XXXXX •   A XXXXX of Product A contains; XXXXX In addition, Product A contains the following non-medicinal ingredients; XXXXX. •   The Product A label states XXXXX. •   Product A has a Drug Identification Number (XXXXX) XXXXX (Product B) •   Product B is a non-carbonated liquid vitamin and mineral concentrate. •   Product B contains no fruit, fruit juice or fruit flavouring. •   Product B contains the Non-Medicinal Ingredient: XXXXX. •   According to the Product B label, the directions for use are as follows: XXXXX •   A XXXXX of Product B contains; XXXXX[.] In addition, Product B contains the following non-medicinal ingredient; XXXXX •   The Product B label states XXXXX. •   The label also states, XXXXX •   Product B has a Drug Identification Number (XXXXX). XXXXX (Product C) •   Product C is a non-carbonated XXXXX concentrate. •   Product C contains no fruit, fruit juice or fruit flavouring. •   According to the Product C label, the recommended use is as follows: XXXXX •   The Product C label states, XXXXX •   XXXXX XXXXX (Product D) •   Product D is a non-carbonated fruit-flavoured XXXXX concentrate. •   Product D contains XXXXX •   According to the Product D label, the recommended use is as follows: XXXXX •   The Product D label states, XXXXX •   XXXXX XXXXX Ruling Requested The products are zero-rated pursuant to section 1 of Part III of Schedule VI to the Excise Tax Act (ETA). ...

XXXXX: •   XXXXX; •   XXXXX; •   XXXXX. 9. XXXXX. 10. The proposed fee for the XXXXX Camp is $XXXXX per participant. ... Daily activity choices within the camp program include: •   waterfront XXXXX •   adventure XXXXX •   sports XXXXX •   service XXXXX •   arts XXXXX •   science and technology XXXXX •   out-trips XXXXX. 12. ... Yours truly, Debra Murphy Charities, NPO & Educational Services Unit PSB & Governments Division Excise and GST/HST Rulings Directorate 2006/02/08 — RITS 60810 — [ITC for Tax on Imported Goods] ...

It owns $[…] of equipment (i.e., property) that it leases to customers. ... FinanceCo earns $[…] of exempt revenue from its loan activities and $[…] of taxable revenue from its leasing activities per year. 5. ... The value of this property, based upon book value, is $[…]. 6. It is your view that FinanceCo last manufactured, produced, acquired or imported substantially all of its equipment for consumption, use or supply exclusively (i.e., […][90% or more]) in the course of FinanceCo’s commercial activities based on the following: * property held by FinanceCo (other than financial instruments) is worth $[…]. * $[…] of that property is supplied exclusively in the course of FinanceCo’s commercial activities (leasing). * the remaining $[…] was not last manufactured, produced, acquired or imported, all or substantially all, for consumption, use or supply exclusively in the course of its commercial activities. ...

. / 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 We understand from your […][correspondence], the following: * You have been a non-resident of Canada since [yyyy] and are not registered for GST/HST purposes. * You carry on business, pay taxes and have been a resident of […][Country X] since [yyyy]. * [XYZ] is responsible for […][Province 1] lawyers and paralegals. […]. * You have been a member of [XYZ] since [yyyy] but you do not currently practice law in [Province 1] or elsewhere in Canada. Further, you do not provide [Province 1] law advice anywhere inside or outside of Canada. * You have maintained your membership in [XYZ] since [yyyy] as a “not in [Province 1]” member under class […]. * A professional membership in [XYZ] is required to practice law in [Province 1]. ...

Facts •   XXXXX XXXXX[.] •   XXXXX provides advisory services exclusively to its two subsidiaries; XXXXX[.] •   During 1994 with respect to advisory services from the XXXXX and XXXXX[.] •   The two subsidiaries are incorporated under the XXXXX and operate under the XXXXX as venture capital funds deriving their revenue from interest, dividends, fees, et cetera. •   All the issued and outstanding common shares of XXXXX are owned by XXXXX[.] •   XXXXX[.] •   According to the XXXXX offering memorandum, investors who subscribe for one or more bonds may qualify for Canadian permanent resident status along with their spouse and dependents. Investment is required for a minimum number of years.      Also according to the memorandum, the "main purpose of the Fund is to provide equity or loan capital to establish, purchase, or maintain eligible businesses or commercial ventures,..."[.]      XXXXX[.] •   As established in a telephone conversation with XXXXX, on August 17, 1995, XXXXX is not and has not been charging GST on its supplies of advisory services to the funds. ...