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STATEMENT OF FACTS We understand the facts as follows, based on the information provided, our telephone conversations, and the website […]: 1. […] ([…][the Organization]) is part of […]. ... To ensure [the Event was] successful […], […] [the Organization] enlisted the participation of sponsors. ... The agreement with [Sponsor #1] included the following clauses: […][Clauses from the agreement including sponsorship rights and consideration payable] […] [Sponsor #1 sponsored a video] 12. […] stated that the […] video was shared […][online]. […] Agreement with [Sponsor #2] 13. ...

The Platform may provide refunds for delivery services]. […]: […][The Platform limits its liability for the delivery service to the consumer to the amount paid by the consumer for that service] […] 3. ... The delivery driver provides its services to the Platform, which the Platform provides to consumers or merchants] […][Information on relationship between a delivery driver and the Platform] […] […]: […][Definitions] 4. […][Information on the Platform webpage about refunds to consumers. ... Sincerely, David Phoenix, CPA, CGA Industry Sector Specialist Services and Intangibles Unit General Operations and Border Issues Division GST/HST Rulings Directorate FOOTNOTES 1. […] 2. […] 3. […] ...

USco is in the business of providing […] information to its customers. ... USco purchases some […] information from […], Canco. 6. Canco does not have contact with USco’s customers and is not otherwise involved in the supplies made by USco to its Canadian customers. 7. ... As explained in GST/HST Policy Statement P-051R2, Carrying on business in Canada, the factors that will be considered in determining whether a non-resident person is carrying on business in Canada for GST/HST purposes in a particular situation 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. ...

The statement of account is as follows: Income from sale: $ XXXXX Expenses from Dispersal: Estate Dispersal Services XXXXX $ XXXXX Estate Fees XXXXX $ XXXXX Disposal Fees $ XXXXX Carpet Cleaning $ XXXXX Casual Labour $ XXXXX Bank Fees on Credit Cards $ XXXXX Hardware Supplies $ XXXXX GST XXXXX $ XXXXX •   You also provided a sample covering letter addressed to the Owner that refers to attachments to the letter: the statement of account, the cheque payable to the Owner, XXXXX and a letter of appreciation from a local charity. •   A sample follow-up letter describing a job was not provided. 5. ... For further details and examples of agency relationships, we are enclosing GST/HST Info Sheet GI-009 entitled " Consigned Goods ". ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2005/02/08 — RITS 52141 — Stock Options for Independent Contractors ...

Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 165306 Business Number: […] Dear [Client]: Subject: GST/HST RULING [Application of GST/HST to a Baked Good Product] Thank you for your letter of [mm/dd/yyyy], concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to […] (the Product) sold by […] (the Company). ... It also offers its products to the general public through its retail outlet. […] 4) The Company does not make sales to school authorities. 5) […], the Company now intends to supply the Product in corrugated cardboard shipping cartons, with each carton containing [#] boxes of the Product and each box containing twelve pieces of the Product. ... The individual product wrappings do not contain a listing of ingredients or a statement of nutrition facts. 8) Each inner box will contain the company name, logo, and address, the Product identification (e.g. […][sample product]), the Product weight and quantity (e.g. 12 x 50g), a listing of ingredients, a listing of nutritional facts per product, and a representation that the Product is peanut and nut free. 9) Included on the inner box is the Product’s Universal Product Code (UPC). 10) It is the position of the Company that the labelling of its inner box will conform to the Consumer Packaging and Labelling Act, as does the co-branded product box provided for review. 11) […]. 12) […], all delivery orders placed must be no less than $[…] or [#] cases ([#] boxes) of the Product. ...

In their letter, XXXXX provided the following information: •   XXXXX choose their own locations, which appear profitable based on traffic flow and availability of ABMs in the surrounding area. •   XXXXX negotiated an agreement with the location owner to allow for the installation of an ABM for which they pay a portion of the applicable surcharge amount. •   The surcharge amount varies from XXXXX per withdrawal based on the affordability and need of customers using the ABM. •   XXXXX. fills the ABM with their own cash from their business account. ... In XXXXX opinion, they should be allowed to claim ITCs on the purchase of the equipment to get started in its XXXXX venture because the ABM operations business was started with the following objectives in mind: •   To purchase and install ABMs at potentially profitable locations, establish the business with a view to improve the transaction volume and then find suitable customers who would buy their ABMs along with an established location and pay a certain price which would provide a sizeable profit. •   XXXXX[.] •   XXXXX[.] ... In a letter XXXXX provided to the CCRA, XXXXX confirmed having sold XXXXX ABMs, which according to the documentation we have were placed in the following retail locations: •   XXXXX •   XXXXX •   XXXXX •   XXXXX As for the current status of the ABMs, XXXXX wrote a letter to the CCRA stating that the ABM at XXXXX and the other XXXXX locations were being offered for sale to potential buyers. ...

Une « voiture de tourisme » est défini au paragraphe 123(1) comme une voiture de tourisme ou une voiture de tourisme zéro émission, au sens du paragraphe 248(1) de la [LIR]. Selon ce paragraphe, une « voiture de tourisme » désigne généralement une « automobile » acquise après le 17 juin 1987. ... Bien que la prestation de services de covoiturage commerciaux soit une « entreprise de taxi » aux fins de la TPS/TVH, il n'était pas clair si un véhicule utilisé pour fournir de tels services était considéré comme un « taxi » dans le contexte de la définition d'automobile dans la LIR. ...

The Company produces the Product in [#] flavours; […]. 7. […][Flavour 1] uses the core Product ingredients of […]. 8. ... The Product is gluten free, vegan, raw, paleo-friendly, peanut free, and does not contain refined sugar, dairy, eggs, additives, or trans fats. 10. […]. 11. […]. 12. The Product is a chewy, […] snack food. 13. The adhesive qualities of the […] hold the Product ingredients together […]. 14. ...

VI, partie V, 1(c)                                                                         Téléphone no: (613) 954-8585                                                                         Télécopieur no: (613) 990-1233                                                                         HQR0000360                                                                         Alinéa 1c), partie V, annexe VI                                                                         Fichier #: 11640-4(dc) XXXXX le 29 mai 1997 XXXXX Cher Monsieur, La présente fait suite à la demande de renseignements présentée par XXXXX de XXXXX le 15 octobre 1996, par rapport à la position de notre Ministère concernant l'application de l'alinéa 1c) de la partie V de l'annexe VI de la Loi sur la taxe d'accise (la Loi) aux différents procédés effectués par les commerçants de peaux d'animaux. ...