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STATEMENT OF FACTS Our understanding of the facts based upon your submission of September 26, 2013 and our subsequent conversations […], is as follows: 1. […]. ... According to section […] of the Plan, […], all normal and reasonable expenses incurred in the operation of the Plan and all taxes levied or assessed with respect to the Pension Fund may, at the discretion of [A Co] as the Administrator, be paid from the Pension Fund. 10. […]. 11. ... An example of the discharging of such an expense for which [A Co] has contracted with [C Co] and for which you wish to claim an ITC is as follows: * Sample invoice [#] dated [mm/dd/yyyy], for the amount of $[…] plus $[…] […][GST/HST] was issued to [A Co] from [C Co], a pension consulting firm. * Work is completed by the pension consultant, [C Co]. * The invoice is sent to [A Co] for payment. * The Vice President of Human Resources reviews and approves the invoice for payment. * The Plan service provider, [B Co] is then notified that the funds can be taken from the Plan for payment. * Invoice is paid by the Plan to [C Co]. ...

Specifically, we received the following documents: a.) your incoming letter; b.) […] (Lender 1) documents: i.) […] (the Lender 1 Dealer Agreement), […], and ii.) […] (the Lender 1 Contract); c.) […] (Lender 2) documents: i.) […] (the Lender 2 Dealer Agreement), and ii.) […] (the Lender 2 Contract); d.) […] (Lender 3) documents: i.) […] (the Lender 3 Dealer Agreement), and ii.) […] (the Lender 3 Contract); e.) […] (Lender 4) documents: i.) […] (the Lender 4 Dealer Agreement), ii.) […] (the Lender 4 Contract), and iii.) […][another contract] with similar terms as the Lender 4 Contract, and therefore not referenced in the balance of this response; f.) […] (the Lender 5 Contract); g.) […] (the Lender 6 Contract); h.) […] (the Lender 7 Contract); and, i.) […] (the Lender 8 Contract). ... The key provisions in these transactions, based on the documentation we received, are: * the contract is intended to be assigned to a lender; * upon assignment, the lender is receiving an assignment of a flow of payments provided under the contract (e.g., all amounts due now and over time); * upon assignment, the Dealer is to receive a payment based on the amount to be financed by a customer under the contract; and * the Dealer receives a fee in respect of the assignment of the contract. ... We further rule that a Fee received by the Dealer from * Lender 1 for the assignment of rights under the Lender 1 Contract, * Lender 3 for the assignment of rights under the Lender 3 Contract, or * Lender 4 for the assignment of rights under the Lender 4 Contract forms part of the consideration received for the assignment of the specific Contract, and therefore would not be subject to GST/HST as the assignment is an exempt supply. ...

We have reviewed the website referenced in your submission, […] 5. The ingredients for the products are as follows: Product A: […]. Product B: […]. Product C: […]. Product D: […]. 6. Marketing for Product A states that it can help […]. 7. ... Marketing for Product C includes claims that the product can help […]. 11. ...

The Dealership can provide a loaner vehicle for up to [#] days at $[…] per day without authorization by the DSM. ... The total claim in the amount of $[…], including HST, includes itemized charges for parts, labour and a loaner vehicle charge of $[…]; c. ... The total claim in the amount of $[…], including HST, includes itemized charges for parts, labour and a loaner vehicle charge of $[…] that was claimed under [Program X]; c. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The Product label states: • XXXXX. • XXXXX. • XXXXX. • XXXXX. 11. The XXXXX Website states: • XXXXX. • XXXXX • XXXXX. ... Consequently, supplies of the Product are taxable at 5% GST, or 12 %, 13% or 15% HST as applicable. ...

The [Professional Organization] was incorporated [...] by an Act of Parliament (the "[...] ... The [Professional Organization] sets standards for [...]. 5. In fulfilling its mandate the [Professional Organization] uses an examination process [...]. 6. [...] 7. Upon achieving a satisfactory result on the examination, the [...] receives a certificate [...]. 8. ...

The Company produces and packages the Product in […] […] grams […][containers] sealed with […] covers. 4. The […] cover for the Product contains a universal product code (UPC) for scanning and a listing of the ingredients. 5. ... Words such as “[…]” and “[…]” are printed on the outside of the shipping carton. 9. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The front of the package contains the following information: • XXXXX • XXXXX • XXXXX • XXXXX The front of the box is XXXXX so that an actual XXXXX, with the XXXXX cover, can be seen. 5. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The front of the package contains the following information: • XXXXX • XXXXX • XXXXX • XXXXX The front of the box is XXXXX so that an actual XXXXX, with the XXXXX cover, can be seen. 5. ...

In the Plan document you provided, the Employer is […] responsible […] for the operation and administration of the Plan. […]. 5. […]. 6. […]. ... In [yyyy], […] ([…], (the Insurer)), as funding agent, issued […] (the Policy) to the Employer. ... Under […] the Policy, the Insurer will […][regularly provide to the] Employer a report […] outlining financial activity under the Plan. ...