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The agreement provided does not appear to make any connection between the CBA and the early payment discount. ...

The pertinent definitions in subsection 123(1) of the Excise Tax Act (ETA) in determining whether or not a taxable supply is being made are as follows: "taxable supply" means a supply that is made in the course of a commercial activity; "commercial activity" of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course or in connection with the making of the supply; "business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever, whether the activity or undertaking is engaged in for profit, and any activity engaged in on a regular or continuous basis that involves the supply of property by way of lease, licence or similar arrangement, but does not include an office or employment; "office" has the meaning assigned by subsection 248(1) of the Income Tax Act (ITA) but does not include (a) the position of trustee in bankruptcy, (b) the position of receiver(including the position of a receiver within the meaning assigned by subsection 266(1), or (c) the position of trustee of a trust or personal representative of a deceased individual where the person who acts in that capacity is entitled to an amount for doing so that is included in computing, for the purposes of that Act,, the persons income or where the person is an individual, the person's income from a business; and "office" (subsection 248(1) of the ITA) means the position of an individual entitling the individual to a fixed or ascertainable stipend or remuneration and includes a judicial office, the office of a minister of the Crown, the office of a member of the Senate or House of Commons of Canada, a member of a legislative assembly or a member of a legislative council and any other office, the incumbent of which is elected by popular vote or is elected or appointed in a representative capacity and also includes the position of a corporation director, and "officer" means a person holding such an office. ...

14 July 2000 GST/HST Interpretation 13612- The Supply of Brochures and Catalogues Made to US Customers Unedited CRA Tags ETA 142(1)(a); ETA 142(1)(g); ETA 179(3) Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXXXXXXX 13612 XXXXXJuly 14, 2000 Subject: GST/HST INTERPRETATION The Supply of Brochures and Catalogues Made XXXXX to US Customers Dear XXXXX: Thank you for your letters of December 3, 1998 and January 12, 1999, and the additional information sent electronically to XXXXX, by XXXXX of your office, in connection with your request for a GST/HST ruling regarding the treatment of Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to certain scenarios as outlined below. ...

Commercial activity, as defined in subsection 123(1), includes in paragraph (c) of the definition, the making of a supply (other than an exempt supply) by a person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply, is a commercial activity. ...

Therefore, it is recommended that the direct and indirect costs described be reviewed to determine if these costs (and to what extent) are in connection with the supply of the XXXXX administrative service to the investors. ...

In order for the exemption to apply, it must be evident that there is some connection between the supply of the instruction or tutoring in question, and the curriculum designated by a school authority. ...

In order for the exemption to apply, it must be evident that there is some connection between the supply of the instruction or tutoring in question, and the curriculum designated by a school authority. ...

If loaded on a laptop, XXXXX can be accessed from anywhere in the world, provided there is an Internet connection. ...

It also includes making a supply (other than an exempt supply) of real property, including anything done by the person in the course of or in connection with the making of the supply. ...

It is the Canada Customs and Revenue Agency's position that there must be more than a mere indirect or incidental connection between a service and the underlying property to be considered "in respect of" the property for purposes of the exclusions in sections 7 and 23 of Part V of Schedule VI to the Act. ...