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According to the […] (Pension Plan Rules): • […] there shall be paid from the Fund: (i) the costs of administering the Plan and the Fund, and (ii) all pensions, lump sums, refunds and interest to be paid under the Plan. • […] outlines certain fees and expenses that shall be paid by the Company to the extent they relate to the […] provisions […]. • […], the Company shall pay into the Fund such amounts […], to enable the Fund to provide for payment of all pensions, lump sums, refunds, interest and administrative costs required to be paid under the Plan. 3. ... This amount was comprised of $[…] of GST and $[…] of PVAT. The pension rebate claimed amounted to $[…]. 5. […]. 6. ... The December 2010 fiscal year is not the first fiscal year of the Trust. 9. […]. ...

Shares") at a price of $[...] per share (max. [#] shares / $[...]). ... Management Fee and a [...] Service Fee [...]. The Service Fee is equal to [...]% [...] of the [...] Shares (subject to certain adjustments) held [...] by the Clients [...] [...] the Agreement and the Prospectus both state that the Investment Manager is required to pay to the Dealers a service fee [...] based on the number of [...] ...

En bref, elle comprend non seulement une " entreprise " ou " un projet à risques... de caractère commercial " " sauf dans la mesure où l'entreprise comporte la réalisation par la personne de fournitures exonérées " mais aussi "... la réalisation de fournitures, sauf des fournitures exonérées, d'immeubles appartenant à la personne, y compris les actes qu'elle accomplit dans le cadre ou à l'occasion des fournitures.) ne peut pas s'inscrire à la TPS/TVH. ... -à-d. un " constructeur-locateur ") (Le terme " constructeur " est défini au paragraphe 123(1). ... Le remboursement est égal au moindre de la teneur en taxe (L'expression " teneur en taxe " est définie au paragraphe 123(1). ...

Statement of Facts We understand the following facts from the fax XXXXX and other additional information you submitted. •   XXXXX is a United Sates company and is incorporated in the state XXXXX. •   XXXXX is not registered for GST/HST purposes. •   XXXXX. •   XXXXX has an office in Canada where the Canadian operations are managed. The office is located in XXXXX. •   XXXXX has a full time employee in Canada who manages these operations. •   XXXXX purchases goods in Canada, maintains an inventory of those goods in Canada and sells all of them XXXXX. •   XXXXX contracts with Canadian XXXXX to sell their goods XXXXX. •   XXXXX. •   XXXXX. •   XXXXX has a bank account in Canada. •   XXXXX. •   XXXXX. ... The factors that will be considered in determining whether a non-resident is carrying on business in Canada for GST/HST purposes are listed in enclosed Policy Statement P-051R2, Carrying on Business in Canada and include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ...

27 February 1996 GST/HST Interpretation 11640-3[14]- Supply of Drivers' Services Unedited CRA Tags ETA 133; ETA 142; ETA 165; ETA 169; ETA Sch VI, Part V, 7; ETA Sch VI, Part VII, 6                                                                         Telephone #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         File #: 11640-3                                                                         s. 133, 142, 165, 169 Sch. ... I will now discuss the tax status of the supplies: •   When the drivers' services are supplied to resident freight transportation companies, the services are subject to the GST at 7% under the provisions of subsection 165(1) of the Act. ... Nanner        GAD #: 1614(REG) G. Ryhorchuk E. Vermes ...

The association you are inquiring about has the following membership rights and obligations: •   the membership is to a non-resident professional association; •   the membership dues are XXXXX per year; •   members receive the following benefits: •   professional networking; •   professional recognition; •   leadership opportunities; •   competitions and awards; •   opportunity to be published; •   continuing education; •   on-line education; •   access to experts in the field; •   job referral service; •   access to medical insurance and a credit card program; •   internet discussion forums; and •   voting rights. •   members are entitled to receive the following publications, at no charge: •   a catalogue of publications in their professional field; •   a monthly newsletter; •   a monthly magazine; and •   a quarterly journal. •   non-members could receive both the catalogue and the newsletter for free while they would have to pay $XXXXX per issue in respect of the magazine and the journal; •   magazine cost per year is therefore $XXXXX •   journal cost per year is therefore $XXXXX •   total cost per year: $XXXXX •   members are entitled to a discount on seminars and educational programs at an average savings of approximately $XXXXX Your have asked two specific questions. ... Interpretation Given Question 1: Revenue Canada Policy Number P-077R " Single and Multiple Supplies " provides factors and guidelines to review which the Department will consider in determining whether a supply will be considered to be a single supply or multiple supplies. ... Question 2: We refer you to the GST/HST Guide titled " Information For Non-Resident Suppliers of Publications " (a copy of which is attached). ...

[Individual A] and [...] [Individual B] held (otherwise than as a partnership) title in joint tenancy to [#] parcels of land in [...] ... The parcels bear the following legal descriptions, respectively: a) PID [...] b) PID [...] c) PID [...] d) PID [...] e) PID [...] f) PID [...] g) PID [...] h) PID [...] ... Parcel PID [...] [XYZ] is [#] acres and contains the couple's residence, which was built in 1979. 4. ...

These additional sponsorship features include: a) Joint Venture Team (Cash sponsorship of XXXXX or more): •   full page advertisement in the final program; •   opportunity to XXXXX •   opportunity to make a brief presentation to conference delegates affirming sponsor's support of the XXXXX industry; •   five complimentary conference registrations, with an additional complimentary registration for each additional XXXXX •   opportunity to add XXXXX to the sponsor's Internet home page; •   opportunity to incorporate XXXXX into the sponsor's print materials; •   recognition in all media releases; •   all benefits of the XXXXX level (see below). b) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite (one night); •   complimentary exhibit booth XXXXX value); •   four complimentary registrations XXXXX value); •   early and final registration lists of delegates and exhibitors. c) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite XXXXX •   complimentary exhibit booth XXXXX value); •   three complimentary registrations XXXXX value); •   early and final registration list of delegates and exhibitors. d) XXXXX (Cash sponsorship of XXXXX •   complimentary exhibit booth XXXXX value); •   two complimentary registrations XXXXX value). e) XXXXX (Cash sponsorship of XXXXX •   one complimentary registration XXXXX value). 5. ... Furthermore, it is our ruling that the sponsorship payments are in respect of promotional supplies to which section 135 (see Explanation below) of the Excise Tax Act ("ETA") applies, and in respect of the following taxable supplies: •   conference registrations; •   exhibit booth; and •   hospitality suite. The following promotional supplies made by XXXXX in exchange for the sponsorships fall within the parameters of section 135 of the ETA: •   recognition of sponsor on conference signage; •   recognition of sponsor in promotional brochures; •   sponsor's profile included in the final conference program; •   sponsor's receipt of a full-page advertisement in the conference program; •   recognition of sponsor in conference media releases; •   sponsor's right to include information and promotional items in registration kits; •   sponsor right to use of XXXXX logo on sponsor's Internet home page; •   sponsor right to use of XXXXX logo in sponsor's print materials; •   sponsor's right to express registration and conference check-in (incidental); •   early and final registration lists of delegates and exhibitors (incidental), •   sponsor's right to chair sessions; and •   sponsor's right to make a presentation to delegates.   ...

STATEMENT OF FACTS You have provided the following documents: * […] (the Dealer Agreement), dated [mm/dd/yyyy], outlining […] (the Dealer’s) services provided to […]([…][Company X]). * a Credit Agreement between the Dealer, a Buyer, and […] (the Lender) upon assignment. * the Lender’s […] chart effective [mm/dd/yyyy], and * a Deal Management chart. ... A dealer reserve is based on the loan amount, and is expressed either as a percentage of the loan amount on fixed rate loans over $[…] or a dollar value ranging from $[…] to $[…] on variable rate loans and fixed rate loans of $[…] to $[…]. As an “extra bonus” the chart also indicates an additional $[…] Dealer Reserve is available for […] applications. ...

The claim was made up of the contract price and other additional charges for additional work, expenses, impacted costs and loss of productivity as follows: •   contract price XXXXX •   approved change orders $XXXXX •   additional change orders $XXXXX •   room & board $XXXXX •   additional work $XXXXX •   more additional work $XXXXX •   drawing revision $XXXXX •   misc. items $XXXXX •   disputed work $XXXXX •   time sheet- field work $XXXXX •   disputed work $XXXXX •   impacted costs $XXXXX •   head office costs $XXXXX •   loss of productivity $XXXXX Total $XXXXX Less payment (prior to May 1, 1991) $XXXXX Subtotal $ XXXXX GST $ XXXXX Total amount claimed as owing $ XXXXX including GST XXXXX counter-claimed against XXXXX for the sum of XXXXX but later reduced the amount to $XXXXX[.] ... You advised us that: •   the various amounts claimed by XXXXX were invoiced to XXXXX and booked by XXXXX as receivables prior to XXXXX- after the judgment, XXXXX received the net amount approved by the Court from XXXXX plus the related GST; •   XXXXX called up your office to see if the amount should be subject to GST; •   XXXXX indicated the contract had hundreds of pages, and would not be convenient to forward it to you for review. ... Phil Tang Specialty Tax Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate ...