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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. ... We understand the following […]: […][background information about the profession of sign language interpretation] * […][Individuals] may be employed by organizations (for example, corporations, non-profit organizations and charities) or work as sole proprietors providing sign language interpretation services to individuals or corporations. * You understand that the supply of sign language interpretation services provided by [individuals] who work as professional independent-contracting sign language interpreters (known as freelance interpreters) and who exceed the small supplier threshold of $30,000 in a calendar quarter or any four consecutive calendar quarters is taxable for GST/HST purposes. * Sign language interpretation services are not covered under any provincial health care plan in Canada. * You believe the additional cost for GST/HST charged on the supply of sign language interpretation services to service providers, businesses, agencies and private individuals, who may or may not be able to claim the GST/HST back as a credit, could result in a reluctance to provide the necessary accommodations thus potentially discriminating people who are Deaf, […] or Hard of Hearing. * […][The services of professional sign language interpreters are provided to persons who rely on sign language as their primary mode of communication, for example, for medical appointments or appointments in the community.] * […] Interpreting services may be funded by provincial or municipal grants or fee-for-service. * […][X] contracts freelance interpreters to provide sign language interpretation services to such persons and pays the GST/HST on the consideration for those services. ... We understand your view that the supply of sign language interpretation services should be exempt or zero-rated as they assist those who are Deaf, […] and Hard of Hearing. ...

8 January 2016 GST/HST Interpretation 171598- Relief of GST on property or services supplied to band-empowered entities Unedited CRA Tags TIB-039r GST Administrative Policy — Application of GST to Indians, 221(1); 165; Section 87 of the Indian Act; Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / 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. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 171598 Business Number: […] Dear [Client]: Subject: GST/HST INTERPRETATION Relief of GST on property or services supplied to band-empowered entities Thank you for your [correspondence] of July 10, 2015, concerning the application of the Goods and Services Tax (“GST”)/Harmonized Sales Tax (“HST”) to supplies of information technology (“IT”) services and property made by […] (“the Corporation”) to […] (“the Client”). ... STATEMENT OF FACTS The information below has been taken from your […][correspondence], and from Indigenous and Northern Affairs Canada’s website. * The Client is situated on a reserve as defined in the Indian Act. * The Corporation performs IT services on the reserve as well as supplies property (e.g., battery cartridges) to the Client. * […] the Client was not eligible for relief of the provincial sales tax. * Enclosed with your letter of [mm/dd/yyyy] was an invoice by the Corporation made out to the Client showing that the Corporation charged the GST on services and property it supplied. * The Client is claiming that they are eligible for relief of the GST and are not paying any tax invoiced by the Corporation. * The […] Tribal Council (“TC”) has provided the Corporation with a certificate indicating that their head office is on a reserve and that the services and property in question are acquired for band management activities. * The Client is a separate legal entity from the TC. * The Client is the recipient of the Corporation’s supplies of IT services and property, not the TC. * The Client stated […] that it has the same board of directors as the TC, and that it is owned and controlled by the TC. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Factors to consider in determining whether a non-resident person is carrying on business in Canada 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; •   the place from which transactions are solicited; •   the location of 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. ... Yours truly, Dwayne Moore Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2004/07/29 — RITS 53446 — Effective Date of Municipal Rebate at the Rate of 100% ...

Response •   The provision of the engineering service is not within the ambit of subsection 162(1) and is therefor a taxable supply; •   The time of supply is deemed to be at the time the contract is entered into; •   Tax is due at the earlier of the day the consideration is paid or becomes due; •   The provision of subsection 168(2) is operative such that tax becomes payable on each payment. ... Research •   Letter of XXXXX •   P-128 •   P-110 •   Explanatory notes 4. Carlson & Associates Advertising Ltd v The Queen ...

. / 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. ... We understand the following background: • [...] (the "Company") is a Canadian, commercial, [...] corporation registered for the GST. • The Company entered into an agreement with a non-resident service supplier for the refurbishment of equipment that is used in the Company's commercial activities. • The non-resident service supplier is registered for the GST. • The Company's equipment is transported to the registered, non-resident service supplier's location outside Canada where the refurbishment service is performed. • Upon completion of the refurbishment service, the Company's equipment is returned to Canada by the registered, non-resident service supplier who acts as the importer of record and is responsible for paying the assessed import duties and other taxes, including the GST. ... • If the registered, non-resident service supplier is not entitled to an ITC in respect of the GST paid, is the Company able to use section 180 of the ETA? ...

XXXXX and XXXXX, each own XXXXX % of XXXXX, a commercial building located in XXXXX. 2. ... XXXXX has charged and remitted GST on consideration attributable to XXXXX % of the space that XXXXX occupies in the building (i.e., XXXXX %, which is XXXXX ownership interest in the space occupied by XXXXX). 5. ... You have asked us to confirm that no GST is payable with respect to the portion of the premises owned and occupied by XXXXX (XXXXX % of the XXXXX %). ...

Based on the information provided, we understand the following: 1) You are a […] registered nurse. […]. 2) In [yyyy], you began your own business, […], as a health promotion consultant. 3) As a consultant, your work focused mainly on […]. 4) As a health promotion consultant, your client groups were populations in settings such as schools, other community organizations and agencies addressing primary prevention with vulnerable groups such as […]. 5) In your work as a consultant, you provided interventions such as health teaching and health promotion, communicating with individuals, families, groups, communities and populations, collaborating with care providers, directly or indirectly influencing the practice of care providers and/or policy, developing learning resources for nurses and other care providers and collecting health data, specifically as they supported health promotion work with vulnerable or at-risk populations for […]. 6) Also, you […], developed, […] to support information and awareness related to […] lifestyle risks, and so that several health promotion strategies could be employed by public health nurses […] 7) As a health promotion consultant, you also developed training resources for nurses to use with community health center staff regarding health issues, […]. ... Given the preceding, there are three criteria that the supply must meet to be exempt; i.e., it must be a service that: * is rendered by a registered or licensed nurse; * falls within the scope of nursing services; and * is rendered to an individual within a nurse-patient relationship. ... More specifically, you developed, […] programs. These programs were developed to support information and awareness related to, for example, […] and lifestyle risk factors, […] These programs were for the most part to be delivered by health care providers such as nurses. ...

DATE: May 28, 2015 [Addressee] Case # : 161027 SUBJECT: GST/HST INTERPRETATION Eligibility for the Public Service Bodies’ Rebate at the Municipal Rate This […] refers to […] [a request for] clarification on whether two housing projects ([…][Project A] and […][Project B]) which are owned by […] ([…][a provincial body]), but are operated by […] ([…][the Organization]), qualify for the municipal rebate under section 259 of the Excise Tax Act (the “Act”). ... [The Organization] will […] [match persons with housing] […] that best meets their needs. iii. […][Certain organizations are contracted] to deliver Support Services to Tenants. j. ... [There are indicators] […] that [Project B] may be supportive housing, and the tenants were selected based on the requirement that they receive [support] services […]. ...

Vous voulez également savoir ce qui arrive au niveau de la taxe d'accise lorsque des marchandises assujetties à la taxe d'accise sont vendues à un client étranger par un fournisseur canadien qui ne détient pas une licence " E " et que ces marchandises sont retournées au Canada et sont dédouanées aux termes des positions tarifaires 98.13 et 98.14. ... Le mémorandum stipule qu'un fournisseur canadien qui ne détient pas une licence " E " sera tenu de payer la taxe d'accise relativement à ses marchandises retournées à un montant égal à tout remboursement (N15) qui était accordé lorsque les marchandises étaient exportées du Canada. ... Il semble que lorsque le mémorandum D et le règlement ont été intégrés dans les positions tarifaires, le libellé a été changé à " droits de douane ", qui n'incluent pas la taxe d'accise, du mot " droits " dans le mémorandum et le règlement qui lui comprend la taxe d'accise. ...

Par exemple, un fabricant indique dans sa publicité qu'il faut chercher sa tablette énergétique dans l'allée des " grignotines nutritives " du supermarché, alors qu'un autre qualifie certaines de ces tablettes énergétiques de " bonbons nutriceutiques ". ... Pour être visée par cette disposition, une tablette de grignotines devrait généralement comprendre un mélange d'ingrédients qui ont été " pressés " sous forme de tablette. ... Les produits appelés " mélange montagnard " sont un exemple de ce genre de mélange de grignotines. ...