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Yours sincerely, Ivan Bastasic Manager Border Issues Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate Encl.: Section 1.4 of Chapter 1 of the GST/HST Memoranda Series Customs Memorandum D8-2-25 Value of Imported Goods (GST/HST) Regulations c.c.: Ivan Bastasic Jeff Frobel Legislative References: Sections 212, 214, 215, 252 of the Excise Tax Act NCS Subject Code(s): I1645-3-5 ...

23 March 2001 GST/HST Interpretation 7404- Subcontractors' Progress Payments Unedited CRA Tags ETA 123(1) invoice; ETA 152(1)(c); ETA 168(2); ETA 168(7)(b) Excise & GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXXXXXXX Case: 7404XXXXXBusiness Number: XXXXXMarch 23, 2001 Subject: GST/HST INTERPRETATION Subcontractors' Progress Payments Dear Sir: Thank you for your letters of November 27, 1997 and March 16, 2000 (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to progress payments received by subcontractors. ...

A supply of IPP is also considered to be made in a particular province if the "place of negotiation" ("Place of negotiation" is defined as "... the location of the supplier's permanent establishment at which the individual principally involved in negotiating for the supplier the agreement for the supply ordinarily works... ...

Yours truly, Douglas Wood, CGA Rulings Officer General Operations Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate c.c.: John Sitka Gunar Ozols Douglas Wood XXXXX Legislative References: section 232 of the ETA section 181.1 of the ETA subsection 123(1) of the ETA- "consideration" B-042 XXXXX XXXXX NCS Subject Code(s): R-11610-1 11610-6 ...

Part VI of Schedule V includes, in section 2, a "supply made by a public institution of any personal property or a service, but not including (...)". ...

These comments are not rulings and, in accordance with the guidelines set out in section 1.4 of Chapter 1 of the GST/HST Memoranda Series, do not bind the Canada Customs & Revenue Agency with respect to a particular situation. ...

Although the meals are "provided to" the students by R in this situation, the supply would be "made to" (Note that under the definition of "recipient" in subsection 123(1), the recipient is "the person who is liable under the agreement to pay (the) consideration" and that "... any reference to a person to whom a supply is made shall be read as a reference to the recipient. ...

16 January 2002 GST/HST Interpretation 37916- GST/HST on Commissions Unedited CRA Tags ETA 142; ETA 144.1; ETA 222(1); ETA 225(1); ETA 228(2); ETA Sch VI, Part VII, 3(c); ETA Sch VI, Part VII, 5.1; ETA Sch IX, Part V, 1; ETA Sch IX, Part V, 2 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, Ontario K1A 0L5XXXXX XXXXX XXXXX XXXXX XXXXXXXXXX File #: 37916January 16, 2002 Subject: GST/HST INTERPRETATION GST/HST on commissions Dear XXXXX: This is further to your written request to Patrick McKinnon of October 5, 2001, in which you forwarded a question from XXXXX concerning the tax treatment of commissions paid to a travel agent. ...

. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. ...

Specifically, variable B of this subsection is the total of amounts each of which is an amount of tax that would have become payable in respect of the consideration paid for a casino operating service if subsection 188.1(4) of the ETA did not apply and the consideration was equal to an amount determined by the formula: B1- (B2 + B3), where B1 is the consideration paid for the casino operating service without reference to subsection 188.1(4); B2 is an amount determined by multiplying a particular amount of salaries, wages and other remuneration paid by the operator to its employees by the extent to which the particular amount was a cost to the operator of providing the casino operating service; and B3 is the total of all amounts determined by multiplying an amount that is in respect of a supply of property or a service made by the distributor, or an amount paid by a distributor, to an employee or person related to an employee that the employee is required to include in his income for the year under section 6 of the Income Tax Act (i.e., taxable benefits), by the extent that this amount is a cost to the distributor of supplying the casino operating service. ...