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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. ... Predominant Element, "Whether Arranging For A Financial Service" (i) Importance of Predominant Element •   In accordance with case law (i.e. ... Ivan Bastasic Director Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate 2007/12/11 — RITS 88737 — Re: XXXXX; Whether Certain Amounts Are Promotional Allowances For Purposes of Section 232.1 of the ETA ...

Included in your inquiry was a submission from [the Company]s representative, […]. ... He further submits that even if the [driving] services are not freight transportation services, the […] [towing] services […] should be considered to be freight transportation services. ... Based on [the CRA's] position, which is supported by the TCC in Andrews, […] [towing] services, would also not be considered freight transportation services if […][the vehicles] were not being transported […] by a vehicle owned by [the Company]. ...

(iii) The consideration for the supply does not include the excise duty as: (a) the duty is not an amount payable for the supply by operation of law and (b) it is not "any tax, duty or fee (...) that is payable by the recipient, or payable or collectible by the supplier, in respect of that supply or in respect of the production, (...) consumption or use of the property (...)". ... In addition, paragraph 154(2)(a) of the ETA provides that the consideration for the supply of wine includes any "(...) duty (...) imposed under an Act of Parliament (...) that is (...) payable or collectible by the supplier, in respect of that supply or in respect of the production, importation, consumption or use of the property (...)". ... Legislative References: •   Excise Tax Act (ETA): subsection 123(1) definitions of consideration, supply; sections 133; 134; 154; 165;•           Excise Act, 2001 (EA1) June 13, 2002 Royal Assent / July 1, 2003 implementation date): section 2 definitions of alcohol ("Spirits or wine"), beer, spirits, wine; Part IV (Alcohol): sections 59-158, subsection 135(3), 138(2); sections 136, 137, 139.•   Excise Act R.S., c. ...

GuerraCase #: HQR0001691File #: 11755-6August 6, 1999 Subject: GST/HST INTERPRETATION PROPOSED LAW/REGULATION Dear XXXXX Thank you for XXXXX letter of February 23, 1999, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your operations. ... Promotion of the supplier's products is to be carried out in any or all of the following ways: •   advertising the products and/or brand name in flyers distributed to the public; •   exhibiting signs or posters in its outlets advertising the products and/or brand name; •   broadcasting the products and/or brand name in radio and television commercials; and •   discounting the sale price of the distributor's products through promotional sales. ...

26 February 1997 GST/HST Interpretation HQR0000503- Tax Status of Indian Band Management Activity Unedited CRA Tags ETA 191; ETA 257; ETA 259; ETA 148(1); ETA 169(1); ETA 240(1)                                                                         HQR0000503                                                                         File No.: 11872-1                                                                         February 26, 1997 XXXXX Dear XXXXX The Real Property Division and myself would like to thank you for the opportunity to comment on your draft response of November 28, 1996, to the XXXXX XXXXX an Indian band under the Indian Act. ... Interpretation 2 Section 123 of the ETA, provides that the commercial activity of a person means "... ... Pèpin- Small & Medium Size Enterprises Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Ottawa, ON K1A 0L5 ...

25 June 1997 GST/HST Interpretation HQR0000435- Expense Claims for Telemarketing Tickets Sold by a Charity Through an Agency Unedited CRA Tags ETA 169                                                                         File no. HQR0000435                                                                         June 25, 1997                                                                         XXXXX Dear XXXXX This is in response to a note dated November 22, 1996 sent by XXXXX of your office. ... This treatment is illustrated in the following hypothetical example: Example: Charity's gross revenues: 5,000 tickets sold @ $20 each = $100,000 Less expenses charged by telemarketing company: (   60,000) Subtotal (net profit) $  40,000 Less management fee charged by telemarketing company (   20,000) Amount kept by charity $  20,000 In this example, the $80,000 that the charity does not receive represents consideration paid to the telemarketing company for services provided, and this consideration has two components: $60,000 for expenditures plus a management fee of $20,000. ...

They subsequently deregistered effective June 30, 1993. •   The Association purchases tokens from a manufacturer. ... (i.e. $466.29 + $33.71(GST) = $500.00 for tokens with a face value of $500.00) In the letter referenced above, XXXXX suggested that the tokens are in the nature of financial instruments. ... Jones Director General Tax Policy Policy and Legislation XXXXX Excise/GST c.c.:      Don McColl             XXXXX regional office             Application team ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... This information must include: •   details of the supplier (name, address, telephone number, GST/HST registration number); •   details of the recipient (name, address, telephone number); •   details of the supply (description of accommodation, number of nights, price); •   the GST/HST charged; and •   proof that the amount was paid (e.g., copy of cancelled cheque, wire payment confirmation number). ... Yours truly, Jacqueline Russell, CGA Services and Intangibles Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2008/02/14 — RITS 98614 — Application of GST/HST to Supplies of Dried Fruit ...

16 February 1996 GST/HST Interpretation 11650-7[2]- Input Tax Credit Entitlement and Removal Expenses Unedited CRA Tags ETA 175; ETA Sch V                                                                         11650-7 (pl)                                                                         Section 175 & Sch. ... These expenses are considered to be removal (relocation) expenses incurred by the registrant to relocate the employee; •   in their letter dated XXXXX, the registrant requested a GST interpretation as to whether they would be entitled to claim an ITC with respect to the GST paid on the removal expenses; •   in your letter dated XXXXX, it is stated (based on the answer to Q10747 in the Q. ... Jones Director General Applications Division GST Rulings and Interpretations GAD #: 1568 (REG) c.c.: M. ...

15 September 1995 GST/HST Interpretation 11845-2[9]- The GST Status of the Supply of the Pesticide Unedited CRA Tags SOR/91-39 Sch 1(4)                                                                         11845-2(MB) Doc: 2438G Ref: Ss 1(4) of Agri & Fish Regs.                                                                         ...