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. / 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. GST/HST Rulings Directorate 5th floor, Tower A, Place de Ville 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 247663 Business Number: […] Dear [Client]: Subject: GST/HST interpretation proposed law/regulation- Strata-titled townhomes and the purpose-built rental housing (PBRH) rebate Thank you for your correspondence of May 6, 2024, concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to strata-titled townhomes and the purpose-built rental housing (PBRH) rebate. ...

13 August 1998 GST/HST Interpretation HQR0000242- Employer Contributions Made Into Union Trust Funds Unedited CRA Tags ETA 123(1); ETA 149(1); ETA Sch V, Part VII, 1                                                                         Telephone: (613) 954-5021 Fax: (613) 990-1233 XXXXX HQR0000242 XXXXX                 11735-1 (pl) XXXXX Subsections 123(1) & 149(1) XXXXX                 Section 1, Part VII of Schedule V XXXXX                                                                         August 13, 1998 Dear XXXXX This is in response to your previous letters and several subsequent telephone conversations regarding the application of the GST/HST to contributions made by employers into various employee benefit plans operated as union trust funds. ...

. •   On April 1, 1997, the harmonized sales tax (HST) replaced the goods and services tax (GST) and the provincial sales tax (PST) in the three participating provinces of Nova Scotia, New Brunswick and Newfoundland with a harmonized tax rate of 15%. To the extent that supplies are taxable supplies (which are not zero-rated), tax must be collected at the harmonized rate. •   In 1996, a revised treatment for input tax credits in respect of used goods and the new trade-in approach came into effect. ... Yours truly, Gisèle Prévost, CGA Officer General Operations & Border Issues Division GST/HST Rulings and Interpretations Directorate Encl.: Legislative References: 153(4) ETA NCS Subject Code(s): I-65009 ...

Subsection 10(1) of the Regulations provides, in part, that when there is to be a single final recipient of a supply of a computer-related service (such as Web site hosting) made by a particular supplier, and the recipient acquires the supply under an agreement with the particular supplier or another supplier, the supply is made in a particular province if the final recipient avails itself of the service at a single ordinary location in that province, and either •   the particular supplier maintains information sufficient to determine that location; or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ...

30 June 1995 GST/HST Interpretation 11846-3[1]- Application of GST to Funding Received by the Unedited CRA Tags ETA Sch V, Part VI                                                                         11846-3 (LFR)  XXXXX Manager, Interpretation and Services                              XXXXX Tax Services Office XXXXX                                                                                 June 30, 1995 Dear XXXXX: This is reply to XXXXX enquiry of March 16, 1994 in which he asked whether we agree with the opinions expressed in his letter regarding the application of GST to funding received by the XXXXX. ... As indicated in Schedule B of the Agreement between the XXXXX and the XXXXX, " XXXXX. ... All of the activities carried out by the XXXXX are made in furtherance of its principal goal of providing confidential assistance, through counselling and other related services, to individuals experiencing personal problems (e.g. emotional/psychological concerns; marital/relationship conflict; drug & alcohol abuse problems). ...

17 July 1995 GST/HST Interpretation 11635-3- Link Between Consignment Sales and Carrying on Business in Canada Unedited CRA Tags ETA 240(3)(b)                                                                         11635-3 (gjor)  XXXXX Interpretations and Services  XXXXX District Office Excise/GST                                                                           July 17, 1995 This is in response to your E-Mail dated October 18, 1994, concerning the above subject. ... In that case, Geigy, a Montreal drug manufacturer which shipped annually about $450,000 worth of its product to British Columbia in response to orders received and filled in Montreal, was held not to be " carrying on business" in British Columbia. ... Jones Director General Tax Policy GST Rulings & Interpretations Policy and Legislation Branch- XXXXX sign-off: Mitch Bloom c.c.: Imposition Team G. ...

The application of the GST to the aforementioned supplies of real property by the XXXXX will be as follows: •   the sale of House A and the land reasonably necessary for its use and enjoyment as a place of residence will be exempt under section 2 of Part I of Schedule V to the Act, with excess land exempt under section 9 of Part I of Schedule V, •   the sale of the vacant lot will be exempt pursuant to section 9 of Part I of Schedule V, and •   the sale of House B and the land that was placed on the market in May of this year will be exempt pursuant to section 2 of Part I of Schedule V, with any excess land exempt under section 9 of Part I of Schedule V. 3. ...

22 October 1998 GST/HST Interpretation HQR0000589- Subdivision of Lot and Subsequent Sale Unedited CRA Tags ETA 123(1) builder; ETA 123(1) supply; ETA 191(1); ETA 196.1; ETA 208(2); ETA Sch V, Part I, 2; ETA Sch V, Part I, 9                                                                         GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario XXXXX XXXXX XXXXX XXXXX Case: HQR0000589 XXXXX                 File: 11870-5; 118702; 11950-2; 11950-6 Attention: XXXXX October 22, 1998 Subject: GST/HST INTERPRETATION Subdivision of lot and subsequent sale Dear Mr. ... Secondary issues (a) & (b) XXXXX has provided us with comments on the facts and transactions in question. ... Yours truly, Michael Wolff Real Property Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate Legislative References: Excise Tax Act, subsection 123(1) builder, supply Excise Tax Act, subsection 191(1) Excise Tax Act, section 196.1 Excise Tax Act, subsection 208(2) Excise Tax Act, Schedule V, Part I, section 2 Excise Tax Act, Schedule V, Part I, section 9 NCS Subject Code(s): 118702; 11950-2; 11950-6 ...

In the context of the arrangement in this case, it does not appear that the establishment obtains ownership of the crafts, nor that it is a recipient of a supply of the crafts, for various reasons including: •   The agreement between the parties does not contemplate, either explicitly or implicitly, a transfer of ownership of the crafts from the crafter to the establishment. XXXXX[.] •   There is no indication in the agreement that the establishment has agreed to purchase the crafts at any time. ... If crafts are sold through the booth, the establishment becomes entitled to charge a XXXXX fee to the crafter, which, in the context of the arrangement, would be analoguous to a commission. •   The sales fee is to be calculated as a percentage of the total value of the crafter's sales. ...

Interpretation Given This interpretation is based on the following assumptions: •   the LDC supplies the electricity to the retailer who, in turn, supplies the electricity to the consumer; •   the nature of the supplies made to the consumer under either billing option are that of separate supplies made by the retailer and the LDC, for example, supplies of electricity are made by the retailer and supplies of distribution services are made by the LDC, both of which occur simultaneously; and •   the LDC is not an agent of the retailer and vice-versa. ...