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Nous comprenons que: * […] (le « preneur ») a conclu une entente pour louer l’aéronef suivant de […] (le « bailleur »), un non-résident avec qui le preneur n’a aucun lien de dépendance. Type d’aéronef Numéro du modèle Numéro de série Immatriculation […] […] […] […] * Le contrat de location commence le [jj/mm/aaaa] et se termine le [jj/mm/aaaa]. * L’aéronef sera importé à […] le [jj/mm/aaaa] et sera exporté le [jj/mm/aaaa]. * Au terme d’un bail conclu avec le bailleur, le preneur ne doit pas détenir l’aéronef au Canada pendant plus de 24 mois. ... Veuillez agréer, […], l’expression de mes sentiments distingués. 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 ...

(FinanceCo), and [...] (Service Provider), [...] have entered into a [...] ... The first group of services are the [...] [A] Services (section [...] of the Agreement). ... A few examples of such services are provided below: • [...]: on-line application entry and processing of applications based on FinanceCo's selected criteria. • [...]: post cardholder financial adjustments such as balance and cash and finance charges. • [...]: creating cardholder file with account information such as account balance and posting all pending authorizations to cardholder accounts through on-line enquiry. • [...]: processing and rendering of billing statements. • [...]: embossing, issuing, reissuing and replacing cards. • [...]: on-line statements, account cycle and miscellaneous history. 7. ...

XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX XXXXX XXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX •   XXXXXXXXX XXXXX XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX XXXXX XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX Interpretations Requested 1. ... The XXXXX would appear to address two separate supplies: •   Supply by XXXXX, consideration for which is based on XXXXX total, and •   Supply of research services supplied by the Institutions. ... The determination of the value of the consideration in Canadian currency is made on: •   the day that GST/HST is payable; or •   such other day as is acceptable to the Minister. ...

. / 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. ... (Footnote 1) Based on this information, forestry may be considered farming and […] [a] farmer can contract out operations and functions and still meet the definition of a farmer as long as they are responsible for the overall farming operation. ... Yours truly, Janet Pelletier, CPA, CGA Rulings Officer Fuel Charge Unit Excise Tax and Fuel Charge Division Excise and Specialty Tax Directorate FOOTNOTES 1 Income Tax Folio S4-F11-C1, Meaning of Farming and Farming Business – Canada.ca, section 1.1      - 2-       ...

When applying these facts, we are again in agreement with you that the total GST payable on the lease payment is determined to be $25.90 per month when using the three step approach: Step 1: Calculation of the Monthly Finance Charge Selling price of the new vehicle before GST: $20,000 Less: trade-in Allowance     5,000 Adjusted capital cost $15,000 Add: residual value   11,000 Finance Base: $26,000 Monthly Finance Charge: $26,000 (Finance Base) x.00782 (money factor) $      203.32/mth Step 2: Calculation of the Monthly Depreciation Charge Adjusted capital cost $15,000 Less: residual value   11,000 Depreciation Base: $  4,000 Monthly Depreciation Charge: $4,000 (Depreciation Base) ÷ 24 months:        166.67/mth GST Base: $     369.99/mth Step 3: Calculation of the GST Payable on the Monthly Lease Payment 7% x $369.99/mth (GST Base) $25.90/mth Example #3: (letter, July 30, 1996) Facts Provided: •   XXXXX (the "dealer") leases a new vehicle to a non-registrant; •   Lease period on the new vehicle leased from the dealer: 24 months •   Agreed value of the new vehicle: $20,000.00 •   Agreed value of the trade-in vehicle: $  5,000.00 •   Lien against the trade-in vehicle (owed to financial institution): $  2,000.00 •   Agreed credit given on the trade-in vehicle ($5,000- $2,000): $  3,000.00 •   Residual value (i.e., option price) on the leased new vehicle: $11,600.00 •   The monthly lease payment is calculated as follows:      Total vehicle price: $20,000.00      Less: agreed credit given on the trade-in vehicle     3,000      Net lease cost: $17,000      Monthly lease payment:      Net lease cost x acquisition factor ($17,000 x.047290) $      803.93      Less: residual value x residual factor ($11,600 x.037002)         429.22      Monthly lease payment: $      374.71 •   The monthly sales tax lease payment is calculated as follows:      Total vehicle price: $20,000      Less: trade-in allowance     5,000      Net sales tax lease cost $15,000      Monthly sales tax lease payment:      Net sales tax lease cost x acquisition factor ($15,000 x.047290) $     709.35      Less: residual value x residual factor ($11,600 x.037002)        429.22      Monthly sales tax lease payment $     280.13 •   The dealer then prepares an addendum to the lease which discloses the monthly lease payment, the sales tax lease payment, the amount of the lien and the GST payable as shown in Appendix C to your letter entitled XXXXX; •   Immediately after the lease is executed, the lease and the leased new vehicle are sold by the dealer to XXXXX. ... The vehicle subject to the lease is then sold by the dealer to the lessee for an amount equal to the residual value (i.e., $11,600); Response: •   We agree that the monthly GST payable calculated on the monthly sales tax lease payment (determined above and in Appendix C to your letter) will be equal to: 7% x $280.13/month = $19.61/month; •   We also agree that the dealer is required to collect GST from the lessee on the full consideration paid by the lessee to acquire the vehicle pursuant to the purchase option (i.e., 7% x $11,600 = $812); Example #4: (letter, July 30, 1996) Facts Provided: •   Same facts as example #3 except that the trade-in has an agreed value of $15,000 and a lien of $12,000 for a net trade-in allowance of $3,000 (and the lease payments remain at $374.71/month) Response: •   Using the same method of calculation and money factors provided in Appendix B to your letter, the sales tax lease payment will be calculated as follows:      Total vehicle price $20,000      Less: trade-in allowance   15,000      Net Lease Cost $  5,000      Lease payment:      Net price x acquisition factor ($5,000 x.047290) $     236.45      Less: residual value x residual factor ($11,600 x.037002)        429.22      Monthly sales tax lease payment $ Nil      Monthly GST payable (7% x $Nil) $ Nil •   Again, the dealer will collect GST in the amount of $812 (i.e., 7% x $11,600) from the lessee on the full consideration paid by the lessee to acquire the vehicle at the time the purchase option is exercised. Example #5: (letter, July 30, 1996) Facts Provided: •   XXXXX (the "dealer") leases a new vehicle to a non-registrant; •   Lease period on the new vehicle leased from the dealer: 24 months •   Agreed value of the new vehicle: $20,000.00 •   Agreed value of the trade-in vehicle: $11,000.00 •   Amount of the trade-in allowed by the dealer as a trade allowance $  7,000.00 •   Customer receives cheque for remaining value of the trade-in $  4,000.00 •   Lien against the trade-in vehicle: $Nil •   Residual value (i.e., option price) on the leased new vehicle: $11,600.00 •   Monthly lease payment to the customer on the leased new vehicle: $     185.55/mth Response: •   Proposed new subsection 153(4) of the ETA provides in paragraph (c) that the value of the consideration for the supply (i.e., the leased vehicle) is deemed to be equal to the value of that supply less "... the amount credited to the recipient in respect of the trade-in... ...

STATEMENT OF FACTS You submitted the following documents for our review: * Statement of Adjustments, […]. * […][Agreement A], signed and dated [mm/dd/yyyy]- only portions of this agreement were provided. * Statements on letterhead of […] indicating lease payments on each of [mm/dd/yyyy], [mm/dd/yyyy] and [mm/dd/yyyy]. * Land Transfer Tax Statement evidencing conveyance of property […]. * […][Lease Agreement]- an incomplete document: it does not identify the parties to the agreement nor is it signed or dated. ... (Footnote 3) * Tenant means [X] and its successors and permitted assigns. * Term means the initial term of the Lease as set out in […] (see below). ... Each statement sets out the following details: * Income Collected – […] $[…] * Expenses Incurred – […]$[…] Although the terms of the lease payments are not set out in the documentation provided, the statements suggest the lease is paid on a monthly basis. 7. ...

The goals of the Association are: •   To represent XXXXX. •   To provide continuing education programs XXXXX. •   To remain non-profit and to ensure all funds collected by the Association are returned to the membership for the betterment of the members. •   To provide certification for qualified members. •   To promote the career of XXXXX to the profession, the community and to government XXXXX. ... The Association has two membership categories: Voting Members •   XXXXX •   XXXXX Non-voting Members •   XXXXX •   XXXXX •   XXXXX Membership in the Association provides members with many benefits, including the following: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX the total fee for membership in the Association is $XXXXX. ... Gaudet Charities, Non-Profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate XXXXX  Legislative References: 123(1) "non-profit organization"; sections 17 & 18 of Part VI of Schedule V. ...

We understand that [...] (the "Lessee") has entered into an agreement to lease the following aircraft from [...] ... The details are as follows: Aircraft Type Model Number Serial Number Registration Number [...] [...] [...] [...] • The lease agreement for this aircraft is for a period beginning on [mm/dd/yyyy] and ending on [mm/dd/yyyy]. • This aircraft will be imported at the Airport of Entry ([...] ... /registration number [...]) has been held in Canada by the lessee under a lease with the lessor will be 21 months on [mm/dd/yyyy]. ...

On [mm/dd/yyyy], [...] (the Individual) entered into a purchase and sale agreement (the Purchase Contract) with [...] ... On [mm/dd/yyyy], the final statement of adjustments was approved and became effective; it includes the following information: * Buyer- the Company, as bare trustee and nominee of the Individual; * Adjustment date- [mm/dd/yyyy]; * Completion date- [mm/dd/yyyy]; and * Possession date- [mm/dd/yyyy]. 5. ... The Real Estate Appraisal Division of CRA has provided the following information: * [...]- transfer of the Property from the Vendor to the Company, dated [mm/dd/yyyy]; * [...]- the borrower is the Company; digital signature is the Individual, as authorized signatory of the Company; * [...]- transferor/borrower/party is the Individual, as Covenantor (see below); * [...], includes the following:- borrower/mortgagor is the Company;- the Individual is "Covenantor"; the terms of the [...] provide, in part, that the Covenantor will pay or cause to be paid to the Mortgagee all amounts owing by the Mortgagor; to unconditionally guarantee full performance and discharge of all obligations of the Mortgagor; that the Covenantor is jointly and severally responsible with the Company. 7. [...]. ...

According to the agenda you submitted, the Conference will consist of […][numerous] sessions on […] and […], a […] plenary presentation, an opening and welcomes session with keynote speakers, [#] plenary sessions, [#] parallel sessions, [#] brainstorming sessions and one session on the future [field of research] priorities, [#] sessions on […], one session on […], and [#] sessions for poster and sponsors exhibit. ... The last day has [#] sessions for a […] meeting on the [conference] outcomes and future [field of research] priorities. ... You are expecting [#- #] delegates, with more than 75% of these delegates coming from outside of Canada. 10. ...