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In accordance with the Management Agreement, the General Partner appoints the Manager to direct the day-to-day business, operations and affairs of the Partnership as described in the Partnership Offering Memorandum including: a) furnish a continuous investment program for the Partnership; b) invest, reinvest and manage the investments of the Partnership; c) lend securities of the Partnership; d) sell, transfer, or dispose of any property or securities held in the Partnership; e) borrow cash and/or securities for and on behalf of the Partnership; f) select the dealer or broker and negotiate commissions or service charges in connection with portfolio transactions; g) execute all documents and perform all other acts necessary or appropriate to manage the investments of the Partnership without obtaining prior approval or direction from the General Partner or its authorized agents; h) exercise all rights, powers, options, privileges, and other powers incidental to ownership of the securities in the Partnership; i) execute or cause to be executed proxies respecting the voting of securities held by the Partnership at all meetings of holders of such securities; j) participate in the marketing and distribution of Units in the Partnership; k) provide administrative support to the General Partner when requested; l) determine the portion of the Partnership assets to invest or to hold uninvested and provide liquidity for the redemption of the Units in the Partnership; and m) provide any information required for reports or registrations to be filed with any governmental authority on behalf of the Partnership or the General Partner. 4. ... In particular, the Partnership Offering Memorandum notes that the Manager, among others, is entitled to reimbursement from the Partnership for all costs and operating expenses actually incurred in connection with the business of the Partnership, including administrative fees and expenses of the Partnership such as: investment manager’s fees; accounting and legal costs; insurance premiums; custodial fees; registrar and transfer agency fees and expenses; bookkeeping and record keeping costs; communication expenses; organizational and set up expenses; regulatory fees and expenses; all reasonable or non-recurring expenses; and fees and expenses relating to the Partnership’s portfolio investments, including the cost of securities, interest on borrowings, commitment fees, brokerage fees, commissions and expenses, and banking fees. ... This determination will generally be based on written agreements, between the person providing the service and the person’s client, detailing the actions, responsibilities and obligations of the person in connection with the supply. ...

The Corporation acquires the breast implants for consumption, use or supply in the course of its activities undertaken at the Facility in connection with both reconstructive and cosmetic breast implant surgery performed by physicians on patients of the Corporation. 3. […]. 4. […]. 5. ... Accordingly, a supply of an institutional health care service, such as a medical or surgical prosthesis installed in a health care facility, is not an exempt supply included in Part II of Schedule V if it is a cosmetic service supply or it is made in connection with a cosmetic service supply. ... Conclusion As explained above, depending on the circumstances in which it is made, a supply of a medical or surgical prosthesis may be subject to the GST/HST, zero-rated or exempt: * When the supply is made by the operator of a health care facility, the medical or surgical prosthesis will be either an exempt supply or a taxable supply that is subject to the GST at the rate of 5% or the HST at the rate of 12%, 13% or 15% (depending on the place of supply). * In contrast, when the supplier is a manufacturer or distributor there is usually a discrete supply of property that has no connection to a particular surgical procedure, e.g., the recipient acquires the medical or surgical prosthesis for general inventory purposes. ...

Under XXXXX unless otherwise provided under the agreement, XXXXX is responsible for maintaining and paying all costs in connection with the Retail Portion and the Corporation is responsible for maintaining and paying all costs in connection with the Condominium. ... 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. ...