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XXXXX a Web site; XXXXX. •   XXXXX offers memberships for a fee XXXXX. Individuals who purchase memberships XXXXX and the right to enter the Web site XXXXX. •   XXXXX. •   XXXXX employs individuals, who are resident in Canada, to search the Internet XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   XXXXX. •   The server is located in Canada XXXXX. •   XXXXX makes this supply to both residents and non-residents of Canada. ... Leyton Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2006/03/17 — RITS 60371 — Application of GST/HST on Vehicle "Trade-ins" ...

STATEMENT OF FACTS We understand the following from […] [the] fax, additional documents including a sample […][agreement] (footnote 1) (the Agreement), the company’s website […], and [various] telephone conversations held between […] and […][CRA officials]: 1. […] ([…] [ACo]), […], is a non-resident corporation that is registered for the GST/HST under Subdivision d of Division V. 2. ... According to […] the Agreement: […] 14. [ACo] retains exclusive ownership of all applicable copyrights, trade secrets, patents, and other intellectual property rights in the Software according to […] the Agreement, […] […] 15. ... The [Representatives] shall pay any […] taxes, fees or duties […], including but not limited to, taxes due and owing on amounts due or collected from end-users to the [Representative]. […] 31. ...

STATEMENT OF FACTS Based on the information you provided, our understanding of the facts is as follows: Parties involved: * […] (Vendor) – sets up ATM bank machines (i.e., sells equipment & related software licences), * […]([…][X]) – assignor and subsequently lessee, * […] (Lessor), a non-depository short term credit institution that provides primary equipment financing through leases – assignee and subsequent lessor All parties are registered for GST. Facts: * [X] enters into an “Acquisition Agreement” to acquire equipment & software licenses from the Vendor. * [X]’s acquisition of the equipment does not include the purchase of any software which is licensed to [X] by the Vendor. ... It is not clear how this particular taxable supply was accounted for, since the full Equipment Lease Agreement [#] was not submitted […]. […] […] [ABC] has referred to section 165 of the ETA to say that “every recipient of a taxable supply made in Canada” shall pay GST/HST based on the “value of the consideration for the supply”. ...

BACKGROUND INFORMATION From [...], we understand that the relevant facts are as follows: 1. [...] (the General Partner) is the sole general partner of [...] ([...] [Limited Partnership A]). ... The General Partner is also the general partner for two other limited partnerships: [...] ([...] ...

10 April 1996 GST/HST Interpretation 11640-2- Application of the GST to the Supply of Intangible Personal Property Unedited CRA Tags ETA Sch VI, Part V, 10                                                                         Tel. #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         Files #: 11640-2(dc)                                                                         Sch. ... Jones Director General Applications Division GST Rulings and Interpretations Policy and Legislation Branch Enclosures GAD #s: 1559 & 1570 (REG) c.c.: R. ...

Tour 1 includes [...] nights short-term accommodation in Canada in [...]. ... Tour 2 includes [...] nights short-term accommodation in Canada in [...]. ... Tour 6 includes other elements such as meals [...], air transfers between [...], and ground transfers [...]. 22. ...

[X] acquired […] vacant land […] for $[…] on [mm/dd/yyyy] in an arm’s length transaction. ... [Information about] Registration of clients […][in Program B]. [#] documents are developed upon [Program B] registration […][including]: […][Agreement B], and […][Document B]. 11. […][Terms of Agreement B]: […]. 12. […][Key points in Document B]: […] 13. ... Based on review of the Facility’s floor plan and our phone conversation of [dd/mm/yyyy], we understand the following: * [Program B] is mainly operated […][at] the Facility, which […][accommodates] […][# clients]. […][Information about accommodations at the Facility] * The following rooms [in the Facility] are also used by the [Program B]: […] * […][More information about administration of the Facility] 22. […] 23. […][A supplemental agreement] between the [Organization] and [X] dated [dd/mm/yyyy] [includes specific terms and] governs the funding and obligations between the two parties. […] 24. ...

In addition to the above user fees, the Authority also derives funding through municipal levies and provincial grants. […] […] The Regional Municipality […] 8. The Regional Municipality […] (the “Region”) is an upper-tier municipality […]. ... The Agreement 10. […], the Authority and the Region entered into a Service Agreement (the “Agreement”) […]. ...

Schedules [...] and [...] to the agreement outline the activities and specific responsibilities of the physician. ... Schedule [...] lists the medical services to be performed by the physician relating to: • Management, treatment and disposition of all patients of the Department; • Arranging for the admission, consultation and disposition on patients; • Arranging follow-up of patients with family physicians and specialists; • Reviewing diagnostic test results; • Taking regular calls and giving advice to physicians from referring facilities; • Ensuring documentation is maintained on patients; • Providing medical direction to ambulance personnel; and • Participating in the development and implementation of departmental quality of care initiatives. ... Major responsibilities are listed in Schedule [...] to the agreement and include: • Managing the provision of patient care related to the Department: ­ Ensuring the provision of medical services in the Department by medical staff, residents and students through review, analysis and evaluation of the work of members of the Department; ­ Establishing, reviewing and revising policies, procedures and guidelines related to patient care; and ­ Providing advice on medical equipment acquisition, maintenance and disposal. • Education and teaching: ­ Delivery of medical education programs in the Department; ­ Delivery of continuing professional learning programs of the Department in cooperation with the [...]; ­ Defining and contributing to the teaching and instructional programs of other health care programs; ­ Ensuring that education and teaching activities complement patient care within the Department; and ­ Contribute to the development of regional, national, and international networks to attract high quality clinicians, educators and students and to facilitate professional development and collaboration. • Research: ­ Encourage, facilitate and support research activities of the Department; ­ Encourage and facilitate the acquisition of external grant funding; ­ Ensure that department members follow approved research protocols and administrative procedures as required; ­ Support and encourage the publication of research results in journals and presentations at professional seminars; and ­ Promote teamwork and collaborative research activity. • Quality management: ­ Coordinate the establishment of quality standards and indicators of patient care, monitor clinical performance and undertake appropriate corrective action to strive for the attainment of appropriate standards in patient care; ­ Ensure that the Department and its members comply with all policies, bylaws, rules and regulations, and standards established by accreditation bodies; and ­ Manage any complaints involving departmental members. • Professional human resources: ­ Assist in the development and ongoing review of a medical human resource plan; ­ Recruit new members of the medical staff; ­ Advocate for adequate resourcing of Department members; and ­ Provide mentoring and annual performance evaluation of Department members. • General management: ­ Participate in program planning, coordinate the implementation of new programs and services and assist in their evaluation; ­ Annually prepare a written report of the Department's activities; ­ Establish and periodically update departmental policies and procedures; ­ Represent the Department on committees as required; and ­ Other duties as required. ...

Paragraph […] provided that the buyers agreed to pay a brokerage fee of $[…] (Fee) plus applicable GST and any other applicable tax. ... On [mm/dd/yyyy], the lawyers sent a letter to [the client] and the broker with an enclosed cheque for $[…] which sum represents the balance of the settlement monies of $[…], less the sum of $[…] for legal fees. ... On [mm/dd/yyyy], the broker issued a cheque to the company for the sum of $[…] ($[…] plus [$][…] GST less a deal fee of $[…].) ...