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30 May 1997 GST/HST Interpretation HQR0000629- Registered Pension Plans- Unedited CRA Tags ETA 259 XXXXX Case #: HQR0000629                                                                         File: 11585-32                                                                         May 30, 1997 XXXXX This letter is in response to your facsimile received April 07, 1997 with respect to the registered pension plans of XXXXX[.] ... XXXXX has also instructed XXXXX to allocate XXXXX of "Asset & Fund Administration Fees" as Plan Trust Expenses and the remaining XXXXX as Employer Expenses. ... Allocation Method Our understanding is that Asset & Fund Administration Fees (AFA Fees) are charges for both trustee and custodial services provided by the trust company. ...

29 January 2015 GST/HST Interpretation 162974- Supply of boat tours Unedited CRA Tags ETA 163(3), ETA 165, Indian Act: 87, TIB-039 GST/HST Administrative Policy — Application of GST/HST to Indians; 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. ... STATEMENT OF FACTS We understand from your […][correspondence] that: 1. you are making this inquiry on behalf of your client who is an Indian (Footnote 1) under the Indian Act; 2. your client is […] registered for GST/HST purposes whose business activities consist of […], providing […] boat tours (“the boat tours”) by canoe and […](“the boat”), and operating a […] and convenience store on a reserve in [Province X]; 3. your client sells tickets for the boat tours from his convenience store that is located on a reserve; 4. a guide accompanies the participants on the boat tours that last for […] hours to […] hours. ... The boat tours go out around […] and return to [location A]. The water from which the boat tours depart is ocean and is not part of the reserve; 6. your client will provide lunch to the participants if requested, but the lunch must be ordered and paid for […] days in advance of the boat tour. […] shows the price for the lunch separately from the tour. ...

Drive-through rapid COVID-19 testing services (Service 1) * The test is administered by a registered nurse (RN) at the Client’s testing site. * The customer registers, books a time slot, and pays online. * The customer is charged a single fee for both the test kit and the administration of it. ... Virtual consultation for COVID-19 self-testing (Service 2) * The consultation is done with an RN. ... "         ...

As well, I had requested information on the following questions: •   Who do the assets used by the XXXXX belong to XXXXX? •   Who approves the books and records of XXXXX at year-end? •   Is the office of XXXXX on a reserve? ... Yours truly, Karen Bennett Aboriginal Affairs Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2007/03/21 — RITS 81870 — Acquisition of Farmland Held in Joint Tenancy ...

You have provided us with the following documents: • XXXXX • A letter from XXXXX stating that XXXXX had remitted GST in error in respect to Surcharge Fees received pursuant to agreements with ABM suppliers as well as the application for the rebate (the Letter); • The XXXXX Agreement entered into XXXXX between XXXXX and XXXXX (the Agreement); • The XXXXX Agreement entered into XXXXX between XXXXX and XXXXX As both agreements contain essentially identical provisions, the tax status of the supplies provided by XXXXX to XXXXX and to XXXXX will be the same. ... It does not include the power source or communication link. • "ABM Services" is defined as the services set out in XXXXX. • XXXXX. • "XXXXX Sites" is defined as XXXXX locations as set out in XXXXX. • "Interchange Charge" means the payment collected by XXXXX from the Switch Connector for each completed transaction. • "Surcharge" means the payment collected by XXXXX from each account from which funds are withdrawn as part of each transaction completed using the ABM Equipment. • "Switch Connector" means the entity that provides access to a payment network such as XXXXX. 5. ... XXXXX of the Agreement provides that XXXXX will: • prepare the sites, including electric power source and communication link; • perform ABM Services; • allow XXXXX access to the ABMs for the installation of ABMs and the performance of ABM Services, and • provide security for the sites. ...

D'après ce que j'ai compris, l'or que vous avez l'intention d'importer ne correspondrait pas à la définition de " métal précieux " aux fins de la TPS/TVH. ... Aux fins de la TPS/TVH, l'or mi-ouvré est généralement taxable au moment de l'importation, étant donné qu'il n'est pas sous forme brute et qu'il ne répond pas à la définition de " métal précieux ". ... La définition suivante de " or sous forme brute " a été fournie par les douanes: en masses, grenailles, grains, lingots, barres coulées, etc., ainsi qu'à l'état natif séparé de sa gangue, sous forme de masses, pépites, cristaux, etc. ...

Based on the information provided and a "single vs. multiple supplies" analysis as set out in Policy P-077, our interpretation as to whether the supplies listed in b) through i) in Fact 5 are an element of a single supply of instruction or a separate supply is as follows: •   lesson materials which relate to the courses: an element of a single supply of instruction; •   textbooks: a separate supply; •   novels: a separate supply; •   laboratory kits: a separate supply; •   deposits on loan kits: a separate supply; •   compulsory audiocassettes: an element of a single supply of instruction; •   optional audiocassettes: a separate supply; •   deposits on compulsory videocassettes: an element of a single supply of instruction; •   deposits on optional videocassettes: a separate supply; •   computer disks: a separate supply. 2. ... Such an analysis would include discussions of the following concepts: •   inputs vs. supplies; •   number of suppliers/recipients; and •   terms of invoice/contract/agreement. ... In order to categorize or determine the nature of the supply, the following criteria may be used: •   description of the supply; •   objective of the supply; •   agreement between the parties; •   intent of purchaser. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... As stated in P-209R, unless there is strong evidence to the contrary, the following expenses are viewed as not incurred as agent of the client: • fees for expert reports/attendances (i.e., fees paid to have an expert prepare a report in respect of a particular proceeding or to have the expert attend an examination; the expert may also be required to attend other meetings or to appear as a witness in court); • fees to obtain court transcripts (i.e., fees paid to obtain a transcript of court proceeding in respect of a particular proceeding); • telephone charges; • photocopy charges; • courier costs; • costs for travel by the lawyer (or others working on a client's file); and • postage. ...

Interpretation Given The Hotels should obtain the following information in order to confirm that they can pay or credit an amount on account of the Rebate to a Tour Operaror: •   the name of the Tour Operator, •   confirmation that the Tour Operator is a non-resident, •   confirmation that the Tour Operator is not registered for GST/HST purposes, •   confirmation that the Tour Operator supplies the short-term accommodation in the ordinary course of its business to another non-resident person, •   confirmation that payment for the accommodation was made at its business address or at the address of its agent outside Canada, •   the name of the non-resident person who acquired the accommodation from the Tour Operator if that person is not a non-resident individual, and •   the name(s), physical address(es) and arrival and departure dates of the non-resident individual(s) to whom the accommodation was made available. ... We have met all of the following requirements: •   We are not a resident of Canada. •   We are not registered for GST/HST. •   We supplied the short-term accommodation or tour package in the ordinary course of our business to another non-resident. •   Payment for the short-term accommodation or tour package was made at: –   our business address (see below) outside Canada, or, –   the address(es) outside Canada of our agent(s) which is (are) attached. •   The short-term accommodation or tour package being supplied to the other non-resident was made available to a non-resident individual. •   The individual using the room was a non-resident (verified at check-in). ... (Name and address of the tour operator) (Name of authorized officer of the tour operator) (Signature of authorized officer of the tour operator) 2007/08/30 — RITS 94916 — XXXXX Fruit Juice XXXXX ...

The parties will not be considered to be partners but rather independent contractors operating jointly under an agreement. •   The landowner agrees that it shall not permit the installation of any equipment associated with the provision of laundry services in, on or at the building, by any party other than XXXXX •   The landowner will: •   supply at its own cost and expense: all utilities required in the operation of the laundry services including all water, gas, electricity, drainage, sewer outlets, ventilation systems, and janitor service to the premises; •   arrange for and pay the cost of all licenses, permits, provincial sales tax or other taxes which may arise as a result of providing the laundry services to the residents of the building; •   be responsible for the security of the building, premises and automatic laundry equipment used; •   keep the equipment and premises clean; •   carry insurance on the building and premises; and •   not interfere with XXXXX access to the premises in order to carry out its obligations under this agreement.  XXXXX will: •   connect at its own cost and expense the equipment to the electric, gas, water, and sewer connections in the premises and do all work needed for the installations of the equipment; •   carry insurance on the equipment; and, •   repair or replace the equipment when required. •   Title to the equipment shall at all times remain with XXXXX regardless of the nature of installation.   ... These factors are as follows: •   a contribution by the parties of money, property, effort, knowledge, skill or other asset to a common undertaking; •   a joint property interest in the subject matter of the venture; •   a right of mutual control or management of the enterprise; •   expectation of profit, or the presence of "adventure", as it is sometimes called; •   a right to participate in the profits; and •   most usually, limitation of the objective to a single undertaking or ad hoc enterprise. ...