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Statement of Facts We understand the facts to be as follows: [...] (the Company) is an importer, blender and packager of loose-leaf tea. ... The [#] smaller tins are also considered to be usual containers in the case of Product B. INTERPRETATION As noted above, Product B is a gift set composed of [#] small tins of tea within a gift box. ...

Statement of Facts Our understanding of the background facts is as follows: The following three organizations (collectively referred to XXXXX supply courses largely related to occupational first aid courses according to the requirements of XXXXX •   XXXXX The businesses operated for a number of years with the understanding that their courses (listed below) were exempt from GST: •   XXXXX The businesses are registered for GST purposes; they have reported small amounts of GST collectible and claimed ITC's on all of their purchases. ... Ruling Requested •   Under our policy, do the above organizations fall within the meaning of "vocational school" as described in section 1 of Part III of Schedule V to the ETA? •   Is it our view that courses supplied by the above organizations are exempt under sections 6 or 8 of Part III of Schedule V to the ETA? ...

Application of the Place of Supply Rules A portion of the supply of points made by way of sale by XXXXX is deemed to be made in Canada in accordance with subparagraph 142(1)(c)(ii) on the basis that: •   the supply of the points is a supply of intangible personal property and not a supply of real property by way of lease, licence or similar arrangement, •   the points represent a non-specific right to use or occupy more than one real property in various locations, •   the exercise of the non-specific right to use or occupy XXXXX timeshared properties may result in the acquisition of a specific right to use real property situated in Canada, and •   subsection 143(1) does not operate to deem the supply to be made outside Canada as XXXXX is registered under Subdivision d of Division V of the Act at all relevant times during which the supplies under review are made. Similarly, a portion of the supply of points made by way of sale by XXXXX is deemed to be made outside Canada in accordance with subparagraph 142(2)(c)(ii) on the basis that: •   the supply of the points is a supply of intangible personal property and not a supply of real property by way of lease, licence or similar arrangement, •   the points represent a non-specific right to use or occupy more than one real property in various locations, and •   the exercise of the non-specific right to use or occupy XXXXX timeshared properties may result in the acquisition of a specific right to use real property situated outside Canada. ...

. / 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 that: 1. […] (the Company) is registered for GST/HST purposes. 2. ... Yours truly, Jill McDonald Goods Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 […] ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... We understand that: • XXXXX. (the "Lessee") has entered into an agreement to lease the following aircraft from XXXXX (the "Lessor"), a non-resident person with whom the Lessee deals at arm's length: Aircraft Type XXXXX Model Number XXXXX Serial Number XXXXX Registration Number XXXXX The lease agreement is for a period beginning on XXXXX and ending on XXXXX • The aircraft will be imported at the Airport of Entry (XXXXX) on XXXXX and will be exported on XXXXX. • The total number of months that the aircraft is to be held in Canada by the Lessee under a lease with the Lessor will not exceed 24 months. ...

. •   Pursuant to XXXXX the XXXXX, a patient of a XXXXX hospital must be under the active care of a legally qualified medical practitioner in order to be admitted to or treated in a XXXXX hospital. ... This indicates that the primary purpose for which a person stays in a XXXXX hospital is to obtain medical treatment. •   XXXXX Accordingly, individuals are at the hospital to receive medical care rather than simply being there as a place to live. •   XXXXX, no one can use a house as a XXXXX hospital unless the person is licenced under the XXXXX. ... You indicated that the Vendor's licence was not available. •   It is not evident that the XXXXX or Regulations thereto prohibit the carrying on of medical operations. ...

The assignment agreement provides for the following: •   The assignment will begin on XXXXX but may be extended or terminated upon 2 months notice of either party. It is agreed that no offer of continuing employment will be made by XXXXX during or immediately after the termination of the assignment. •   XXXXX will reimburse XXXXX salary and employee benefits at a monthly rate not to exceed XXXXX- The XXXXX XXXXX shall apply to XXXXX during the period of assignment. 3. During the assignment, XXXXX will perform the following duties: •   Manage the implementation of the XXXXX- Manage the activities related to the XXXXX- Provide other technical and program support to XXXXX in the implementation of other commercial building initiatives including those with the XXXXX XXXXX[.] 4. ...

. / 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, 11th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 186381 Business Number: […] Dear [Client]: Subject: GST/HST RULING GST/HST status of samosas Thank you for your letter of August 15, 2017, concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to the supply of cooked and uncooked samosas (the Product) by […] (the Company). ... The Company has confirmed that [#] insulated pizza delivery bags are on site at the [venue] to keep the cooked samosas warm. 7. ...

Statement of Facts Our understanding of the facts is as follows: •   In your legislation XXXXX all funds from the sale of a prepaid funeral contract are required to be placed into a trust account. •   If a consumer wishes to cancel his or her contract, he or she is able to do so and is entitled to a return of his or her funds plus income earned. •   Under the heading XXXXX under the terms and conditions of the draft prepaid funeral contract provided XXXXX XXXXX Ruling Requested The issue on which you need clarification pertains to the timing of payment of the HST, and former GST, when a funeral home sells a prepaid funeral to a client in the province of XXXXX. 1. ... Based on the information provided, the only amount of GST/HST that is payable to the Seller, who must account for this tax in its net tax and remit any net tax owing, at the time the contract is entered into, is the GST/HST in respect to the XXXXX % administrative fee, as indicated in ruling #1 above. ... Yours truly, Carolle Mercier Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate ...