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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. ... PCO will then contract in its own name with service providers for the following: • the provision of technical advice on design of marketing research; • to conduct market research, surveys and pilot projects; • program design; • the provision of artwork, graphic arts, lithography, photography, printing, sound and film art work; • the provision of multi-media advertising (e.g. on-air advertising on television and radio, advertising space in Canadian edition magazines and newspapers, and advertising using flyers/inserts, billboards and murals; and • promotional items XXXXX. ... The following are a list of factors the Canada Revenue Agency considers when determining whether a non-resident is carrying on business in Canada for GST/HST purposes: • 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 or assets are acquired; • the place from which transactions are solicited; • the location of assets or 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. ...

You have provided us with the following documents: •   a copy of a sample agreement, XXXXX (face of the Agreement); •   the Standard Terms and Conditions, XXXXX (Terms and Conditions); •   and the Appendix to the Standard Terms and Conditions (Appendix) collectively referred to as the Agreement, under which, XXXXX agrees to sell to a customer certain equipment. ... The calculation of the Periodic Payments due under the Agreement is detailed XXXXX as follows: •   The XXXXX Net Price is the consideration payable for the Equipment and is shown on the first line of the calculation. •   The Total is calculated by adding GST/HST and other taxes to the XXXXX Net Price. •   The XXXXX Cash Price is calculated by adding any refinanced amounts to the Total. A note indicates that taxes may or may not be applicable to the refinanced amounts. •   The XXXXX Balance of Principal (A) is calculated by subtracting any down payment to the XXXXX Cash Price. •   A financing charge is calculated separately and identified as a rate per $XXXXX financed (B). •   The Periodic Payment is calculated with the following formula A * B / XXXXX. 11. ...

12 March 1996 GST/HST Interpretation 11650-6[3]- Employee and Partner GST Rebate Calculation for Members of a Partnership Unedited CRA Tags ETA 253                                                                         Telephone: (613) 954-8585                                                                         Fax: (613) 990-1233                                                                         11650-6 (pl)                                                                         Section 253 XXXXX March 12, 1996 Dear Mr. ... You believe that the GST rebate calculation for this period would be based on the eligible expenses deducted in the period by the partner for income tax purposes less any amount claimed as a reserve by the partner; •   You also provided in your facsimile the following illustrative example of a partner's GST rebate claim for 1995 based on the aforementioned facts: XXXXX XXXXX XXXXX XXXXX Your questions are: •   whether the above interpretation (and illustrative example) is correct; and if so, •   whether the Department would consider allowing a full GST rebate in respect of the eligible expenses incurred in the second period (i.e, from Feb. 1, 1995 to Dec. 31, 1995) to be claimed in the 1995 taxation year rather than over the ten year transitional period. ... Jones Director General Applications Division GST Rulings and Interpretations GAD #: 2746 (GEN) c.c.: M. ...

Period up to XXXXX •   XXXXX Co owns 100% of XXXXX Co. •   XXXXX Co owns 60% of Canada 1 Co, Canada 2 Co and Canada 3 Co. •   XXXXX Co owns the remaining 40% of Canada 1 Co, Canada 2 Co and Canada 3 Co. •   XXXXX Co and XXXXX Co are not Canadian residents and are not registrants. •   The Canada Cos are Canadian residents and registrants. •   XXXXX Co owns 100% of XXXXX Co. •   XXXXX Co also owns 60% of Canada 1 Co. •   XXXXX Co owns the remaining 40% of Canada 1 Co. •   XXXXX Co also owns 40% of Canada 2 Co and Canada 3 Co. •   Canada 1 Co owns the remaining 60% of Canada 2 Co and Canada 3 Co. •   XXXXX Co and XXXXX Co are not Canadian residents and are not registrants. •   The Canada Cos are Canadian residents and registrants. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Background Information It is our understanding that XXXXX: •   One of the responsibilities of the Sheriff is to enforce money-type judgments issued by the Courts. •   The Sheriff will seize and sell personal property of judgment defendants under the authority of a Writ of Seizure and Sale. •   The control of the seized personal property remains with the Sheriff until the personal property is disposed of. •   The method most often used to dispose of seized personal property is by public auction. •   Where the Sheriff engages the services of an auctioneer, the auctioneer becomes agent of the Sheriff to sell the seized personal property. •   The auctioneer advertises the sale of seized personal property separately from any other sale items. ... Yours truly, Susan Mills Specialty Tax Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate c.c.: XXXXX Alyson Trattner, Manager, Services and Intangibles Unit, Excise and GST/HST Rulings Encl.: Legislative References: 183(3), 177(1.2) NCS Subject Code(s): I-11643-1, 11643-3, 11725-3 2004/06/25 — RITS 50842 — Timing Issue- Obligation to Account for Tax- Sales Accrual on Open Orders ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The trade confirmation identifies: •   The underlying product; •   The deal type; •   The description i.e., what the buyer pays and receives; •   Seller and Buyer information, including commission rate; and •   The party that executes the trade (i.e., the individual broker). 5. ... Yours truly, Kirk Moore Financial Institutions Unit Financial Institutions & Real Property Division Excise and GST/HST Rulings Directorate 2007/02/09 — RITS 76905 — XXXXX Music Cards ...

Under the terms of this Agreement, XXXXX was to act as a general contractor and was to develop and construct a condominium complex for a fixed price of $ XXXXX, which was allocated as follows: $ XXXXX for building the complex; $ XXXXX for fixtures and appliances; $ XXXXX for paving; $ XXXXX for fencing; and $ XXXXX for landscaping. 6. Under the terms of the Construction and Service Agreement, XXXXX also agreed to undertake the initial leasing of the project prior to the turnover date and to manage the project during this time for XXXXX for a fee of $ XXXXX. 7. ... Farber XXXXX All Regional I & S Managers Revenu Quebec ...

The agreement provides that XXXXX will render the training services to XXXXX who will travel to Canada on student visas. •   The XXXXX can choose to register with XXXXX under the XXXXX[.] Those students who wish to enroll in either program pay a tuition to XXXXX which includes accommodation and meals supplied at XXXXX facilities. •   XXXXX invoices XXXXX for the budgeted costs to administer these programs plus an additional amount per student, on a cost-plus contract, for services rendered. •   The XXXXX who successfully complete the XXXXX receive XXXXX while the students who successfully complete the XXXXX[.] •   The students are XXXXX residents who enter Canada under a student visa only and return to XXXXX upon completion of their studies. ... For further information, please refer to Policy Statements P-229 and P-231, entitled " Definition of "Vocational School ["]" and " Courses that Qualify for Exemption ", respectively. ...

Although the policy provides that GST returns will not be adjusted to account for unclaimed input tax credits (ITCs) that do not offset an increase in tax liability, it is our view that the Department may wish to exercise discretion pursuant to subsection 296(2) of the Excise Tax Act [.] Given that Policy P-149 " Administrative Policy Regarding Adjustments to the GST Return " was in place prior to April 1995, the client should have been advised at that time to claim the ITCs in the next reporting period as opposed to advising the client five months later. ... Vallières Chief Program Policies & Procedures Section Small & Medium Business Enterprises Division MacDonald Building 123 Slater, 8th floor             D. ...

Since it is a designated hospital authority, this person would claim an additional GST/HST rebate of 33% for the non-creditable tax charged in respect of its purchases used in the operation of the public hospital as determined by the formula "A x B x C" provided in subsection 259(4), but substituting: •   the reference to "prescribed percentage" in element "A" of the formula with 33%, i.e., the applicable prescribed percentage of 83% less 50%; and •   the reference to "designated activities" in element "C" of the formula with activities engaged in by the person in the course of operating a public hospital. ... If the total non-creditable tax charged during a claim period for the purchase of medical supplies was $100, and 60% of the medical supplies were used in the operation of the public hospital and the remaining 40% was used in the operation of the medical clinic and the long-term care facility, the person would calculate the GST/HST rebate payable in respect of the purchase of the medical supplies as follows: •   claim 50% of $100 of total non-creditable tax charged PLUS •   an additional amount based on the formula "A x B x C" where: "A" is 33% (83% less 50%) "B" is $100 (total non-creditable tax charged) "C" is 60% (the extent to which the medical supplies are used in the course of operating the public hospital) = ($100 x 50%) + (33% x $100 x 60%) = $50 + $19.80 = $69.80- total rebate for the claim period for the GST paid on medical supplies To summarize, a person's entitlement to the GST/HST rebate at the higher prescribed percentage is not based on the nature and character of the services provided by the person. ...