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C Co. will charge a fee to US Co. for the services it provides in connection with bookings of accommodations made in Canadian and non-resident hotels. ...

The only other place that the term is used in connection with the ETA is in the Disclosure of Goods and Services Tax Regulations: "(3) In the case of a supply of a parking space for which the consideration is paid by depositing coins in a parking meter, the prescribed manner is either the manner set out in subsection (1) or giving public notice that the price for the supply includes the tax. ...

Interpretation Given Based on the information provided, the application of the HST in connection with the above three situations is as follows: Supplies of Memberships to Individuals Supplies of XXXXX memberships by XXXXX are made only to individuals. ...

Under XXXXX of the Municipal Act, the by-law may further provide for refunds of the cost of the extension to the applicant according to a formula based on the number of service connections which could be made by other persons (users) subsequently using the extension. 6. ...

(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 of or in connection with the making of the supply". ...

It is our interpretation that Subsection 141(2) of the ETA provides that anything done by a person in connection with the establishment of a commercial activity is deemed to be part of that commercial activity. ...

You will note that there must be more than a mere indirect or incidental nexus or connection between a service and the underlying real or tangible personal property before the supply will be excluded from zero-rating under Schedule VI, Part V, section 23. ...

Paragraph 3 of the additional services addendum XXXXX provides that although the franchisee is granted the right to provide tax rebate discounting services, the franchisee elects to appoint the franchisor XXXXX as the franchisee's agent, in connection with certain activities. ...

Interpretation Given "Commercial activity" is defined in subsection 123(1) of the ETA as: (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 of or in connection with the making of the supply. ...

Pursuant to subparagraph 6(1)(b)(vii.1) of the ITA, "reasonable" allowances for the use of a motor vehicle received by an employee (other than an employee employed in connection with the selling of property or the negotiating of contracts for the employer) from the employer for travelling in the performance of the duties of the office or employment are not included in computing the income of a taxpayer. ...