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As long as there was a sufficient connection between the deemed importer and the transaction of importing the goods, then the deemed importer could be viewed as liable for duties under the Customs Act and therefore also liable for payment of GST. Agency relationships and certain contractual obligations would be examples of evidence of this connection. 2. ... For this reason, caution should be exercised in those rare instances of convoluted transactions in which the deemed importer appears to have no direct connection with the act of importing. ...

In XXXXX, XXXXX entered into a contract with XXXXX was to provide services as a financial advisor in connection with the Potential Transaction. ... The letter explains that XXXXX was engaged to act as financial advisor to the Board and Special Committee in connection with the Potential Transaction. ... XXXXX was engaged as a financial advisor in connection with the Potential Transaction. ...

28 April 2000 GST/HST Interpretation 30301- The Zero-Rating of Training Services Supplied by Unedited CRA Tags ETA Sch V, Part III, 8; ETA Sch VI, Part V, 18; GST/HST Policy Statement P-229, Definition of "Vocational School" in Section 1 of Part III of Schedule V to the Excise Tax Act; GST/HST Policy Statement P-231, Courses That Qualify for Exemption Pursuant to Section 8 of Part III of Schedule V to the Excise Tax Act XXXXX XXXXX XXXXX XXXXXAttention: XXXXX Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5Case: HQR30301April 28, 2000 Subject: GST/HST INTERPRETATION The Zero-Rating of Training Services Supplied by XXXXX Dear XXXXX Thank you for your letter of February 24, 2000 in which you request two separate interpretations in connection with the application of section 169 and section 18 of Part V of Schedule VI to the Excise Tax Act (the Act), in regards to the training services supplied by XXXXX a GST/HST registrant, XXXXX XXXXX, an unregistered non-resident. ... As mentioned previously, where XXXXX acquires goods and services for use in connection with a zero-rated supply of training services, such acquisitions would generally be viewed as being acquired in the course of XXXXX commercial activities. Accordingly, XXXXX would be eligible for input tax credits, in connection with those goods and services acquired for consumption, use or supply in the course of providing a supply of training services, where the supply is zero-rated under section 18 of Part V of Schedule VI to the Act. ...

Fee for Dial-up ABM connection and limited monitoring — Taxable XXXXX will charge a monthly fee for each Dial-up ABM connected to the XXXXX. ... Dial-up ABMs will not be monitored by XXXXX, as defined in XXXXX above, however, XXXXX will provide limited monitoring of the connection in the XXXXX. ... Network Connection Setup — Taxable This fee is charged for connecting the client's ABMs to client-selected Networks (Interac and/or Cirrus). ...

XXXXX the Agreement provides that the employer shall pay to the employee's lawyer XXXXX on account of legal costs incurred in connection with the litigation and settlement of the matter. 6. The employee agreed in the Agreement to indemnify and save the employer harmless to any claims, charges or demands properly exigible which might be made upon it in respect of obligations in connection with this settlement to the Income Tax Act, the Employment Insurance Act, the Canada Pension Plan, or by any duly recognized federal or provincial taxing authorities in respect of income tax and/or payroll deductions previously withheld, including any legal fees and disbursements incurred in the defence of such claims. 7. ...

26 July 2000 GST/HST Interpretation 25666- Website Maintenance Contract Unedited CRA Tags ETA 142; ETA Sch VI, Part V, 7 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX Case: HQR25666July 26, 2000 Subject: GST/HST INTERPRETATION Website Maintenance Contract Dear XXXXX: Thank you for your letter of January 4, 2000 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your particular situation in connection with the website maintenance contract you have with XXXXX). ... Interpretation Given According to the above information, it appears that the agreement between you and the unregistered non-resident provides, in substance, for the supply of a maintenance service in connection with your customer's website (i.e., a programming service), that is considered to be in respect of intangible personal property. ...

From time to time, the manufacturer XXXXX produces various promotional multi-pack kits in connection with the promotion of the Product. ... The manufacturer is in the business of selling food for human consumption, and does not ordinarily sell or distribute non-food items, except in connection with promotional activities. ...

[A Co] may claim ITCs for the GST/HST paid or payable on expenses described in Fact # 13 incurred in connection with the administration of the Plan where [A Co] is the recipient of the supplies described and to the extent that expenses were incurred in the course of [A Co]’s commercial activity. However, [A Co] is required to account for GST/HST on amounts paid from the Pension Fund in connection with these expenses. 2. ... A commercial activity also includes 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. ...

XXXXX[.] 6. the card member is liable to XXXXX for all charges made in connection with their XXXXX card as stated in XXXXX[.] ... It is stated in your letter that XXXXX cannot distinguish personal charges from business charges on the XXXXX card statement; XXXXX 9. the terms and conditions of XXXXX are very similar to those of XXXXX in that the card members are liable for all charges made in connection with the XXXXX cards issued to them (i.e., provided under XXXXX References in the agreement are also made to the limited role of the company; 10. the liability of the card members is also pronounced in the XXXXX which says that: "... the undersigned individual applicant agrees to be solely liable for all charges incurred with the Card as provided in the terms and conditions of XXXXX[".] 11. as for the company's limited liability, XXXXX states under XXXXX section that: "... XXXXX will send monthly statements of charges to each XXXXX Cardmember, who will be solely responsible for all Charges made in connection with XXXXX Card issued to the XXXXX Cardmember. ...

The XXXXX has not filed an election under section 211 of the Excise Tax Act in connection with the centre. 17. ... Is the XXXXX entitled to claim full input tax credits with respect to the GST paid or payable in connection with the subject expansion project? ... Explanation The XXXXX has acquired construction services in connection with the expansion project that it undertook. ...