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8 May 2002 GST/HST Interpretation 37042- Supply of Telecommunication Services Unedited CRA Tags ETA 123(1) telecommunication service; ETA 165; ETA 142.1; ETA 144.1; ETA Sch IX, Part VII, 1;ETA Sch IX, Part VII, 2; ETA Sch IX, Part VII, 3 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 37042Business Number: XXXXXMay 8, 2002 Subject: GST/HST INTERPRETATION Supply of Telecommunication Services Dear XXXXX: Thank you for your facsimile of August 7, 2001, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) with respect to the supply of telecommunication services. ... Pursuant to paragraph 2(b) of Part VIII of Schedule IX, a supply of a telecommunication service, other than a service of making telecommunications facilities available or of granting sole access to a telecommunications channel, is considered to be made in a particular province if •   the telecommunication is both emitted and received in that province; •   the telecommunication is either emitted or received in that province, and the billing location for the service is located in that province; or •   the telecommunication is emitted in the province and received outside the province, and the billing location for the service is not in a province where the telecommunication is emitted or received. ...

15 August 2002 GST/HST Interpretation 38785[1]- Code 8 General Rebate- Original Documentation Requirement Unedited CRA Tags Indian Act 87; ETA 261 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 14th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX Case Number: 38785August 15, 2002 Subject: GST/HST INTERPRETATION Code 8 General Rebate- Original Documentation Requirement Dear XXXXX: Thank you for your letter of XXXXX regarding a request for a waiver on the submission of original documentation in regards to code 8 general rebates. Interpretation Requested In your letter you suggest that with the implementation of a two-year time limit along with the existing requirement to file original documents there is now a conflict with the requirement by Department of Indian & Northern Affairs (DIAND) to have Indian bands retain their records for a period of three years. ... Yours truly, Cindy Christmas Aboriginal Affairs Unit Public Service Bodies & Government Division Excise and GST/HST Rulings Directorate c.c.: Legislative References: s. 87 of the Indian Act; s. 261 of the Excise Tax Act NCS Subject Code: I-11872-13XXXXX ...

17 June 2002 GST/HST Interpretation 38617- Mortgage Backed Securities- Unedited CRA Tags GST/HST Policy Statement P-077R, Single and Multiple Supplies Marilena Guerra Financial Institutions and Real Property Excise and GST/HST Rulings June 17, 2002XXXXX38617 Subject: Mortgage Backed Securities- XXXXX We are writing in response to your memorandum of January 2, 2002 wherein you request our assistance in determining whether the mortgage backed security arrangement of the XXXXX would be an arrangement which would be subject to GST on the subsequent servicing of the mortgages. ... In determining whether there is a single supply or multiple supplies, we turn to policy statement P-077R " Single and Multiple Supplies ". ...

27 March 2002 GST/HST Interpretation 6428- Application of GST/HST to Indian Trusts Unedited CRA Tags Indian Act 87; Technical Information Bulletin B-039R, GST Administration Policy — Application of GST to Indians Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXXXXXX Case Number: 6428March 27, 2002 Subject: GST/HST INTERPRETATION Application of GST/HST to Indian trusts Dear XXXXX: This refers to your previous letter, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to a trust scenario concerning an Indian band. ... Yours truly, Dwight Kostjuk Rulings Officer Aboriginal Affairs Unit Public Service Bodies & Governments Division Excise and GST/HST Rulings Directorate ...

20 November 2002 GST/HST Interpretation 41962- Whether Executors' Fees are Subject to GST Unedited CRA Tags ETA 123(1) taxable supply; ETA 123(1) commercial activity; ETA 123(1) business; ETA 123(1) office Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXX Case Number: 41962File #: 11750-2November 20, 2002 Subject: GST/HST INTERPRETATION Whether Executors' Fees Are Subject to GST Dear XXXXX Thank you for your letter of XXXXX (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the fees paid by an estate to three executors appointed pursuant to the will of a deceased individual. ... You submit that based on the definitions of "taxable supply", "commercial activity", "business", and "office" in subsection 123(1) of the Excise Tax Act (the "ETA"), the definition of "office" in subsection 248(1) of the Income Tax Act, GST Question & Answer #3d.21, and a finding that in the cases of both the freelance bookkeeper and the lawyer the compensation would be income from an office under the Income Tax Act, the fees would not be subject to GST. 7. In your view the position of the CCRA outlined in GST Question & Answer #3d.21 is not clear with respect to the freelance bookkeeper and the lawyer because the bookkeeper was appointed executor due to XXXXX past working relationship with the deceased individual (i.e. ...

25 June 2002 GST/HST Interpretation 31968- Web Hosting Services Unedited CRA Tags ETA 142(1)(g); ETA 144.1; ETA Sch VI, Part V, 7; ETA Sch IX, Part V Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 31968XXXXXJune 25, 2002 Subject: GST/HST INTERPRETATION Web Hosting Services Dear XXXXX Thank you for your letter received XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your operations. ... This section provides that, when a particular supplier makes a supply of a computer related service and there is one final recipient of the service, who acquires it under an agreement either with the particular supplier or another supplier, the supply is considered to be made in a particular province if there is a single ordinary location at which the recipient avails itself of the service, and: •   the particular supplier maintains information sufficient to determine that location; or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ...

31 July 2002 GST/HST Interpretation 37094- Tax Status of Mortgaging Services Unedited CRA Tags ETA 123(1) financial service; ETA 138; ETA 139 John Nowak Financial Institutions & Real Property Excise & GST/HST Rulings Unit July 31, 2002XXXXX37094 Subject: XXXXX XXXXX All mortgages sold under these programs are on a fully serviced basis. ...

6 June 2002 GST/HST Interpretation 39320- Time Limit- GST 189 General Rebate- Code 8 Unedited CRA Tags ETA 261(3) Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 14th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXXXXXX Case Number: 39320June 6, 2002 Subject: GST/HST INTERPRETATION Time Limit- GST 189 General Rebate- Code 8 Dear XXXXX XXXXX: Thank you for your letter of XXXXX and your follow-up letter received XXXXX. ... The announcement states that effective January 1, 2002 GST/HST rebate claims made by Indian and Indian bands must be filed within two years of paying the tax. ... Yours truly, Cindy Christmas Aboriginal Affairs Unit Public Service Bodies & Government Division Excise and GST/HST Rulings Directorate c.c.: Legislative References: ETA NCS Subject Code(s): I-11873-13 XXXXX ...

31 October 2002 GST/HST Interpretation 34340- Application of GST/HST to Network Services Unedited CRA Tags ETA 123(1) telecommunications facility; ETA 123(1) telecommunication service; ETA 136.4; ETA 142.1(2)(a); ETA 144.1; ETA Sch VI, Part V, 22.1; ETA Sch VI, Part VIII, 2; ETA Sch IX, Part IX, 2; ETA Sch IX, Part IX, 3; SOR/2001-170 1; SOR/2001-170 10 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5Attention: XXXXX XXXXX XXXXX XXXXX XXXXXCase Number: 34340October 31, 2002 Subject: GST/HST INTERPRETATION Application of GST/HST to XXXXX Network Services Dear XXXXX: Thank you for your letter of XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to XXXXX network services. ... Subsection 123(1) of the Excise Tax Act (the "Act") defines a "telecommunications facility" to be "... any facility, apparatus or other thing (including any wire, cable, radio, optical or other electromagnetic system, or any similar technical system, or any part thereof) that is used or is capable of being used for telecommunications". ... Pursuant to this section, a supply of a telecommunication service that consists of making telecommunications facilities available is made in a particular province if: •   all of the facilities that are made available are ordinarily located in that province; or •   where all of the facilities are not ordinarily located in that province, the invoice for the supply of the telecommunication service is sent to an address in that province. ...

18 November 2002 GST/HST Interpretation 38637- Application of GST/HST to supplies to non-residents Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 38637XXXXXNovember 18, 2002 Subject: GST/HST INTERPRETATION Application of GST/HST to supplies to non-residents Dear XXXXX: Thank you for your facsimile to the XXXXX GST/HST Rulings Centre of XXXXX concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your company's supplies. ... Subsection 10(1) of the Place of Supply (GST/HST) Regulations provides, in part, that when a particular supplier makes a supply of a computer-related service and there is to be one final recipient of the service who acquires it under an agreement either with the particular supplier or another supplier, the supply is considered to be made in a particular province if there is a single ordinary location in the province at which the final recipient avails itself of the service, and either: •   the particular supplier maintains information sufficient to determine that location, or •   it is the normal business practice of the particular supplier to obtain information sufficient to determine that location. ... For purposes of the Place of Supply (GST/HST) Regulations, a "computer-related service" includes "... a service involving the electronic storage of information and computer-to-computer transfer of information". ...