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Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 165306 Business Number: […] Dear [Client]: Subject: GST/HST RULING [Application of GST/HST to a Baked Good Product] Thank you for your letter of [mm/dd/yyyy], concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to […] (the Product) sold by […] (the Company). ... It also offers its products to the general public through its retail outlet. […] 4) The Company does not make sales to school authorities. 5) […], the Company now intends to supply the Product in corrugated cardboard shipping cartons, with each carton containing [#] boxes of the Product and each box containing twelve pieces of the Product. ... The individual product wrappings do not contain a listing of ingredients or a statement of nutrition facts. 8) Each inner box will contain the company name, logo, and address, the Product identification (e.g. […][sample product]), the Product weight and quantity (e.g. 12 x 50g), a listing of ingredients, a listing of nutritional facts per product, and a representation that the Product is peanut and nut free. 9) Included on the inner box is the Product’s Universal Product Code (UPC). 10) It is the position of the Company that the labelling of its inner box will conform to the Consumer Packaging and Labelling Act, as does the co-branded product box provided for review. 11) […]. 12) […], all delivery orders placed must be no less than $[…] or [#] cases ([#] boxes) of the Product. ...

The Company produces the Product in [#] flavours; […]. 7. […][Flavour 1] uses the core Product ingredients of […]. 8. ... The Product is gluten free, vegan, raw, paleo-friendly, peanut free, and does not contain refined sugar, dairy, eggs, additives, or trans fats. 10. […]. 11. […]. 12. The Product is a chewy, […] snack food. 13. The adhesive qualities of the […] hold the Product ingredients together […]. 14. ...

STATEMENT OF FACTS The following information was provided in your [correspondence]. 1. […]. 2. […]. 3. ... According to your letter, the Settlement Agreement provides, […], for the following: […] 9. ... The scope of the survey work to be undertaken by [Survey Company X] includes the following: • […][information on activities and land to be surveyed] • Drafting numerous reference plans involving […] computer-aided design (CAD) drafting time. 11. ...

Statement of Facts Our understanding of the facts based on your letter and our subsequent telephone discussions is as follows: •   XXXXX is a non-resident vendor of goods based in XXXXX, US. •   XXXXX acquires the goods on a delivered in Canada basis from XXXXX, a GST/HST registered non-resident company. •   The goods acquired by XXXXX are manufactured and packaged in XXXXX US. by XXXXX and delivered to XXXXX on a FOB XXXXX basis. •   XXXXX has contracted with XXXXX to store the goods until they are sold. •   XXXXX has XXXXX Canadian clients for the goods XXXXX. ... The factors to consider in determining whether, for GST/HST purposes, a non-resident person is carrying on business in Canada in a particular situation include: •   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. ... Yours truly, Jeff Frobel Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2007/01/10 — RITS 82341 — Eligibility to Claim Input Tax Credits (ITCs) in Respect of Hedging Activities ...

Tour 1 includes between [#] and [#] nights of accommodation in Canada. ... Tour 2 includes between [#] and [#] nights of accommodation in Canada. ... Tour 3 includes between [#] and [#] nights of accommodation in Canada. ...

Residents at the Facility have various health care conditions including Parkinson’s disease, cancer, acquired brain injuries, MS, or are post-stroke. […] percent ([…]%) of residents ([#]) are incontinent; […] percent ([…]%) of residents ([#]) experience a form of dementia or related cognitive impairments. […] 10. ... Appendix […] to the agreement reads as follows: […] 12. The physicians each work […] hours a week and will visit residents under their care at least […]. ... Residents at the Facility receive physiotherapy […] and […] dietary services […]. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Statement of Facts •   XXXXX. •   The Company is a Canadian tour operator who resells XXXXX blocks of hotel rooms XXXXX to non-registrant non-resident tour operators XXXXX. •   XXXXX. •   After, July 1, 2006, the Company received an invoice from the hotel for short-term accommodation and was charged GST at 6%. •   XXXXX. ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2006/07/28 — RITS 81356 — Application of GST/HST to Cemetery Products and Services ...

Some examples of services include: •   guide or interpreter services; •   transportation services (e.g., air travel); •   sightseeing excursions; and •   ski lessons. ... The following do not qualify as services as they are property: •   short-term and camping accommodation; •   meals; •   a right to enter or attend an event, such as tickets to a show or a hockey game; •   car rentals; •   ski rentals; •   ski lift passes; •   golf green fees; and •   park passes. ... These persons are: •   a non-resident consumer; •   a non-resident non-registered tour operator; and •   a non-resident non-registered business or organization that is not a tour operator. ...