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On both sides of the machine, there is a connection for attaching a water supply hose. ...

However, there is no indication that XXXXX is itself making any taxable supplies in connection with these services. ...

There is no connection to serving sizes listed on the Nutrition Facts label on the packaging for the purposes of Health Canada labelling requirements. ...

Furthermore and pursuant to subsection 211.1(1), a specified supply is defined as a taxable supply of intangible personal property (Footnote 2) or a service other than: (a) a supply of intangible personal property that (i) may not be used in Canada, (ii) relates to real property situated outside of Canada, or (iii) relates to tangible personal property ordinarily situated outside of Canada; (b) a supply of a service that (i) may only be consumed or used outside of Canada, (ii) is in relation to real property situated outside of Canada, or (iii) is rendered in connection with criminal, civil or administrative litigation (other than a service rendered before the commencement of such litigation) that is under the jurisdiction of a court or other tribunal established under the laws of a country other than Canada or that is in the nature of an appeal from a decision of a court or other tribunal established under the laws of a country other than Canada; (c) a supply of a service that is deemed under subsection 180.1(2) to have been made outside Canada; (d) a supply of a service (i) made to a person in connection with a supply of short-term accommodation made to the person, and (ii) the consideration for which represents a booking fee, administration fee or other similar charge; and (e) a prescribed supply (currently, no supplies have been prescribed). ... Subsection 211.11(2) provides that an indicator obtained in connection with a supply is classified for the purposes of section 211.11 as: (a) a Canadian indicator in respect of the recipient of the supply if the indicator reasonably supports the conclusion that the usual place of residence of the recipient is situated in Canada; (b) a foreign indicator in respect of the recipient of the supply if the indicator reasonably supports the conclusion that the usual place of residence of the recipient is situated outside Canada; (c) a participating province indicator in respect of the recipient of the supply if the indicator reasonably supports the conclusion that the usual place of residence of the recipient is situated in a participating province; and (d) a non-participating province indicator in respect of the recipient of the supply if the indicator reasonably supports the conclusion that the usual place of residence of the recipient is situated in a non-participating province. ... The supplier does not obtain any other information about the recipient in connection with the supply, including any evidence that the recipient is registered for the GST/HST under the regular GST/HST regime. ...

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. ...

We note that you have indicated that the jurisprudence in connection with the Income Tax Act has held that partners of a partnership are considered to carry on the business of the partnership; however, under the ETA, rules pertaining to the activities of partnerships are provided under section 272.1 and therefore, reference must be made to those provisions as discussed above to determine whether a partner acts on account of a partnership or on its own account. ... This determination will be generally 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. ...

An automobile is defined in the ITA as (a) a motor vehicle that is designed or adapted primarily to carry individuals on highways and streets and that has a seating capacity for not more than the driver and 8 passengers, but does not include (b) an ambulance, (b.1) a clearly marked emergency-response vehicle that is used in connection with or in the course of an individual's office or employment with a fire department or the police, (b.2) a clearly marked emergency medical response vehicle that is used, in connection with or in the course of an individual's office or employment with an emergency medical response or ambulance service, to carry emergency medical equipment together with one or more emergency medical attendants or paramedics, (c) a motor vehicle acquired primarily for use as a taxi, a bus used in a business of transporting passengers or a hearse used in the course of a business of arranging or managing funerals, (d) except for the purposes of section 6, a motor vehicle acquired to be sold, rented or leased in the course of carrying on a business of selling, renting or leasing motor vehicles or a motor vehicle used for the purpose of transporting passengers in the course of carrying on a business of arranging or managing funerals, and (e) a motor vehicle (i) of a type commonly called a van or pick-up truck, or a similar vehicle, that has a seating capacity for not more than the driver and two passengers and that, in the taxation year in which it is acquired or leased, is used primarily for the transportation of goods or equipment in the course of gaining or producing income, (ii) of a type commonly called a van or pick-up truck, or a similar vehicle, the use of which, in the taxation year in which it is acquired or leased, is all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income, or (iii) of a type commonly called a pick-up truck that is used in the taxation year in which it is acquired or leased primarily for the transportation of goods, equipment or passengers in the course of earning or producing income at one or more locations in Canada that are (A) described, in respect of any of the occupants of the vehicle, in subparagraph 6(6)(a)(i) or (ii), and (B) at least 30 kilometres outside the nearest point on the boundary of the nearest population centre, as defined by the last census dictionary published by Statistics Canada before the year, that has a population of at least 40,000 individuals as determined in the last census published by Statistics Canada before the year; The ITA also defines a motor vehicle as an automotive vehicle designed or adapted to be used on highways and streets but does not include a trolley bus, or a vehicle designed or adapted to be operated exclusively on rails. ...

It states: "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 of or in connection with the making of the supply; [...] ... [in connection with the contest] suggests that the two activities share the same location, procedures, products, customers, employees, equipment, etc. ...