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9 December 2002 GST/HST Interpretation 37123- Questions Concerning Joint Venture and Agency Unedited CRA Tags ETA Sch VI, Part IV From: Labelle, Raymond Sent: December 9, 2002 To: XXXXX Cc: Trattner, Alyson; Boivin, Marcel; Harding, DonnaCase: 37123 Subject: Questions Concerning Joint Venture and Agency Dear XXXXX: This is in response to your e-mail XXXXX in which you posed questions concerning joint venture and agency issues in the context of the making of supplies through agency relationships. ... Furthermore, the agent is deemed not to have made a supply to the principal of services relating to the supply of the property to the recipient *. ... If that were possible, no apportionment of the sales from the various principals would be necessary in order to determine the tax liability of the parties involved **. ...

3 December 2002 GST/HST Interpretation 39421- Tax Status of Supplies Provided Via the Internet Unedited CRA Tags ETA 123(1) recipient; ETA 142(1)(g); ETA 144.1; ETA Sch VI, Part V, 7; ETA Sch VI, Part V, 23; ETA Sch IX, Part I, 1; ETA Sch IX, Part V, 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 0L5XXXXX XXXXX XXXXXAttention: XXXXX XXXXX Case Number: 39421XXXXXDecember 3, 2002 Subject: GST/HST INTERPRETATION Tax status of supplies provided via the Internet Dear XXXXX: Thank you for your facsimile of XXXXX and the information provided on the telephone by XXXXX on XXXXX to XXXXX concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to supplies made via the Internet. ... This section provides that a supply is made in a participating province in the following circumstances: •   the place of negotiation of the supply is in Canada and the Canadian element of the service is performed primarily (more than 50%) in the participating provinces; or •   the place of negotiation of the supply is outside Canada, all or substantially all of the service is performed in Canada, and the Canadian element of the service is performed primarily in the participating provinces. ... Subsection 10(1) of the Regulations provides, in part, that when there is to be a single final recipient of a supply of a computer-related service (such as a data backup and recovery service) made by a particular supplier, and the recipient acquires the supply under an agreement either with the particular supplier or another supplier, the supply is made in a particular province if the final recipient avails itself of the service at a single ordinary location in that province, 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. ...

21 November 2002 GST/HST Interpretation 36645- Web Site Design, Web Site Hosting, and Web Site Replication Unedited CRA Tags ETA 123(1) service; ETA 142(1); ETA 142(2); ETA 144.1; ETA 165(1); ETA 165(2); ETA 165(3); ETA Sch VI, Part V, 7; ETA Sch IX, Part V, 1; ETA Sch IX, Part V, 2; ETA Sch IX, Part V, 3; ETA Sch IX, Part IX, 3; SOR/2001-170 10 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXX XXXXXCase Number: 36645November 21, 2002 Subject: GST/HST INTERPRETATION Web site design, Web site hosting, and Web site replication Dear XXXXX: Thank you for your facsimile to the XXXXX GST/HST Rulings Centre that was received on XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of Web site design, Web site hosting, and Web site replication. ... 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". ...

16 December 2002 GST/HST Interpretation 40653- Treatment of Revenues Unedited CRA Tags ETA 123(1) service; ETA 141.01; ETA 165 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX Case Number: 40653December 16, 2002 Subject: GST/HST INTERPRETATION Treatment of Revenues Dear XXXXX Thank you for your letter XXXXX (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the treatment of revenues derived from the operation of a nursing home. ... Yours truly, Dwayne Moore Goods Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate c.c.: D. ...

7 May 2002 GST/HST Interpretation 38538- Input Tax Credit Entitlement- Construction of (the Centre) Unedited CRA Tags ETA 227(1); ETA 123(1) improvement; SOR/91-51 21(1) Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX XXXXX Case Number: 38538 11872-2; 11950-1May 07, 2002 Subject: GST/HST INTERPRETATION Input Tax Credit Entitlement- Construction of XXXXX (the Centre) Dear XXXXX Thank you for your letter of September 20, 2001 (with attachments) which has been forwarded to us by XXXXX. ... The SQM provision permitting ITCs on acquisition of real property and on the acquisition of improvements to real property is subparagraph (a)(i) of the description of "C" in the formula for net tax "A + B- C" in subsection 21(1) of the Regulations noted above. This provision permits a PSB, for a particular reporting period in which the SQM election is in effect, to claim ITCs for improvements ("Improvement" for purposes of Part IX of the ETA and the Regulations thereto is defined in subsection 123(1) as: "... in respect of property of a person, means any property or service supplied to, or goods imported by, the person for the purpose of improving the property, to the extent that the consideration paid or payable by the person for the property or service or the value of the goods is, or would be if the person were a taxpayer under the Income Tax Act, included in determining the cost or, in the case of property that is capital property of the person, the adjusted cost base to the person of the property for the purposes of that) made to real property, provided such real property is acquired by way of purchase. ...

18 February 2002 GST/HST Interpretation 6939- Application of GST/HST to a Real Property Development Carried Out by a Trust That is Created by a Status Indian Unedited CRA Tags Indian Act 87; GST/HST Technical Information Bulletin B-039R, GST Administrative 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 XXXXXAttention: XXXXX Case Number: 6939February 18, 2002 Subject: GST/HST INTERPRETATION Application of GST/HST to a real property development carried out by a trust that is created by a status Indian 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 status Indians. ... Yours truly, Dwight Kostjuk Aboriginal Affairs Unit Public Service Bodies & Governments Division Excise and GST/HST Rulings Directorate c.c.: Chron. ...

22 March 2002 GST/HST Interpretation 35196- Treatment of Indian Purchases for GST Purposes Unedited CRA Tags GST/HST Technical Information Bulletin B-039R, GST Administrative 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 XXXXXAttention: XXXXX Case Number: 35196March 22, 2002 Subject: GST/HST INTERPRETATION XXXXX Dear XXXXX: This is in response to your letter of XXXXX, with attachments, to XXXXX in which you question the position taken by the Canada Customs and Revenue Agency (CCRA) in one of its XXXXX, interpretation letters. ... Further, it acknowledges our telephone conversations on this matter, the most recent of which took place on March 6, 2002. ... Technical Information Bulletin B-039R " GST Administrative Policy- Application of GST to Indians " (TIB-039R) reflects this policy guideline. ...

4 October 2002 GST/HST Interpretation 38983- Application of Joint Venture Rules Unedited CRA Tags ETA 273; SOR/91-36 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: 38983October 4, 2002 Subject: GST/HST INTERPRETATION Application of Joint Venture Rules 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 lease of real property by a joint venture operator to a financial institution that is a participant in the joint venture. ... Yours truly, Dwayne Moore Goods Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate c.c.: D. ...

14 August 2002 GST/HST Interpretation 39701- Insurance Indemnification of Bad Debts Unedited CRA Tags ETA 222; ETA 225; ETA 231 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: 39701 11610-4August 14, 2002 Subject: GST/HST INTERPRETATION Insurance Indemnification of Bad Debts Dear XXXXX: Thank you for your letter of XXXXX concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your client's operations. ... Yours truly, John Nowak Financial Institutions Unit Financial Institutions & Real Property Division Excise and GST/HST Rulings Directorate c.c.: Encl.: Legislative References: 222, 225, 231 NCS Subject Code(s): 11610-4 ...

22 October 2002 GST/HST Interpretation 35664- Supply by Agent of On-line Registration Unedited CRA Tags ETA 177(1); ETA 177(1.1); ETA 221(1); ETA 225(1) 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: 35664XXXXXOctober 22, 2002 Subject: GST/HST INTERPRETATION Supply by agent of on-line registration 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 supply of on-line registration for your clients' events. ... XXXXX's client may be: •   a resident supplying event admissions to either residents, non-residents, or both; or •   a non-resident supplying event admissions to either residents, non-residents or both. ...