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1 March 1996 GST/HST Interpretation 11895-1[12]-- Arena Construction Unedited CRA Tags ETA Sch V, Part VI, 20(l)                                                                         File #: 11895-1(on)                                                                         c.n. 465(REG)                                                                         Sch. ...

By [mm/dd/yyyy], [#] of the [#] residential units situated in the Building (that is, […]% of the units) had been leased to tenants, triggering the sale of the Building to the Investor pursuant to the […] Sales Agreement. ... Whether the fact that the Developer sold the Building to the Investor with only [#] of the [#] residential units leased, and [#] residential units vacant, has any relevance for the Developer’s entitlement to the NRRPR for the [#] residential units as claimed. 3. ... The fact that the Developer sold the Building to the Investor with only [#] of the [#] residential units leased, and [#] residential units vacant, will not affect the Developer’s entitlement to the NRRPR for the [#] residential units as claimed. 3. ...

14 February 1996 GST/HST Interpretation 11910-5[3]- GST Rebates- Public College Unedited CRA Tags ETA 123(1) public college                                                                         File: 11910-5(DRM)                                                                         Doc: 2655                                                                         Subsection 123(1) XXXXX February 14, 1996 Subject: GST Rebates- Public College Dear XXXXX I refer to your facsimile transmission of December 1, 1995 wherein you requested a review of policy statement [P]-186 " Funding for Public Colleges ". ... Venne Director Special Sectors GST Rulings & Interpretations c.c.: J. ...

. / 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 consider each of these items to be in respect of a "pension activity" to which section 172.1 would apply. • Services pertaining to the establishment or subsequent amendment of a pension plan or plan trust. • The preparation and filing of actuarial reports, financial reports and other information for a pension plan pursuant to statutory requirements. • Administration services in relation to the collection of pension contributions and payment of pension benefits. • The reconciliation of pension contributions to payroll records. • The maintenance of records pertaining to employee hires, terminations and deaths. • Pension benefit calculations. • Pension adjustment calculations. • Preparation of a pension entity's periodic pension rebate application forms (GST4607) and SLFI returns (GST/HST 494). • Trustee services rendered by the employer or by third parties contracted by the employer. • The retention of a trustee for a plan trust. • Custodial or nominee services for plan trust assets. • The appraisal of plan trust investment performance. • The appointment of an investment manager for a plan trust. • Plan trust portfolio management. • Investment advice with respect to plan trust assets. • Salaries or wages paid to employees who invest or manage funds for a pension entity. • Brokerage, agents' charges and all other property or services relating to the acquisition, utilization or disposal of plan trust assets. • Legal, accounting or auditing services rendered in respect of plan trust assets. ... Accordingly, these would not be subject to the deeming rules of section 172.1. • Third party accounting services supplied to an employer to determine the employer's obligations under section 172.1 of the ETA (i.e., with respect to deemed taxable supplies and the corresponding deemed tax collected). • In the case of a hostile takeover of an employer, actuarial services and the preparation of an actuarial report to determine the liabilities of a pension plan, for the sole purpose of assessing the related financial impact on the assets and liabilities of a participating employer of the plan. ...

Scenario 1 •   XXXXX is resident in XXXXX and is registered for GST/HST purposes XXXXX[.] •   XXXXX creates both doorway /search pages and unique Web sites pertaining to a given product or service XXXXX[.] •   Dar-Ray submits the pages or Web sites to various search engines in hopes of attracting potential customers. •   XXXXX receives a commission XXXXX if someone goes through its search pages or Web site to access the website XXXXX or XXXXX. •   XXXXX receives a commission only if a person XXXXX redirects uses a service or purchases a product from the other Web sites. •   XXXXX[.] Scenario 2 •   Using the same marketing techniques as described in Scenario 1, Web site owners offer to pay a set rate XXXXX for people XXXXX redirects from XXXXX or search pages to it's client's Web site. •   In order to receive the set rate, the person redirected from XXXXX Web site must actually enter the XXXXX Web site(s) beyond the welcome pages. •   XXXXX[.] •   XXXXX[.] ... Also enclosed is GST/HST Memoranda Series Section 4.5.3, Exports — Services and Intellectual Property. ...

2 May 1997 GST/HST Interpretation HQR0000373- The Application of GST to Money and Services Provided by Unedited CRA Tags ETA 135                                                                         File: 11925-6                                                                         Doc: HQR0000373                                                                         Ref: section 135                                                                         XXXXX Attention: XXXXX May 2, 1997 I am responding to your facsimile of October 11, 1996 to XXXXX concerning the application of GST to money and services provided by XXXXX XXXXX has inquired as to the meaning XXXXX of its agreement with the XXXXX XXXXX of the agreement reads as follows: The XXXXX acknowledges that all amounts to be paid in accordance with the provisions of XXXXX of this agreement, shall be payable without any deductions of any taxes, charges or expenses whatsoever. ...

23 July 1996 GST/HST Interpretation 11680-7[5]- Application of Subsection 143(1) to Lease Transactions- Unedited CRA Tags ETA 142(1)(b); ETA 142(2)(b); ETA 143(1)                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 File #: 11680-7(dc) Para. 142(2)(b) & ss. 143(1) XXXXX                                                                                 July 23, 1996 XXXXX Dear Sir: I refer to your request for an application ruling dated April 2, 1996, concerning the application of the Goods and Services Tax (GST) to the supply of tangible personal property otherwise than by way of sale. ...

11 April 1996 GST/HST Interpretation 11650-3[3]- Acquisition of a Motor Home Unedited CRA Tags ETA 199(2)                                                                         Telephone: (613) 954-8585                                                                         Fax: (613) 990-1233                                                                         Subsection 199(2)                                                                         11650-3 (pl) XXXXX April 11, 1996 Re:      Acquisition of a Motor Home Dear Mr. ... Statement of Facts: In your letter you provided the following facts to the Income Tax Rulings and Interpretation Directorate for our consideration: •   XXXXX commercial activity is to provide, among other things, demonstrations on XXXXX techniques throughout the XXXXX with the possibility of extending these services to XXXXX[.] ... Jones Director General Applications Division GST Rulings and Interpretations GAD #: 2841 (GEN) c.c.: M. ...

17 April 1998 GST/HST Interpretation HQR0000175- Application of the Goods and Services Tax to the Service of Accepting Payments on Behalf of the Unedited CRA Tags ETA 123(1) service, 165(1), 221(1)  XXXXX XXXXX GST/HST Rulings and Interpretations Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Road Vanier, Ontario K1A 0L5Case #:  HQR0000175File #:  11595-1; 11720-1File #:  11595-1; 11720-1April 17, 1998 Subject: GST/HST INTERPRETATION Application of the Goods and Services Tax to the Service of Accepting Payments on Behalf of XXXXX Dear Sir: Thank you for your facsimile transmission regarding the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the service of accepting payments on behalf of XXXXX[.]  ... Although no documents were submitted that describe the specific service XXXXX would provide to XXXXX, based on my telephone conversation with you on March 31, 1998, my understanding of the transaction is as follows: •   Clients or applicants for services of XXXXX  will make payments for such services at a XXXXX outlet. •   The client or applicant will deliver a cheque, made payable to the Receiver General for Canada, as well as any applicable XXXXX forms such as an 'XXXXX['.] •   XXXXX will deliver the cheque to a bank for deposit to a Receiver General account and will deliver any XXXXX forms to XXXXX. ... Krawchuk Rulings Officer Financial Institutions Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate Legislative References: ss. 123(1); 165(1); 221(1) NCS Subject Code(s): R  1; 11720-1 Casework Number HQR0000175 ...

26 April 1996 GST/HST Interpretation 11650-10[1]- Clarification of the 6/106ths Factor for Claiming Input Tax Credits Unedited CRA Tags ETA 169; ETA 175                                                                         Telephone: (613) 954-8585                                                                         Fax: (613) 990-1233                                                                         11650-10 (pl)                                                                         Sections 169 & 175 XXXXX April 26, 1996 Dear XXXXX Thank you for your letter dated March 5, 1996, in which you request clarification of our draft Policy Statement P-184: Credit card expenses and the registrant's use of the 6/106ths factor for claiming input tax credits as it relates to XXXXX[.] ... However, please note that we have incorporated your recommended change (i.e., "... one or more written agreements... ... Jones Director General Applications Division GST Rulings and Interpretations Attachment GAD #: 2777 (GEN) c.c.: M. ...