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GST/HST Interpretation

4 April 2011 GST/HST Interpretation 92799 - GST/HST treatment of sale of shares and associated rights to use land

Each site in the Park is serviced for telephone and cable TV connection; however, it is at the discretion of a Member as to whether their particular site is hooked up to such services. ...
GST/HST Interpretation

28 October 2021 GST/HST Interpretation 217144 - Trailing Commissions in the Mutual Fund Industry

The simplified prospectus describes the management fees paid to the Manager in consideration of providing, or arranging for the provision of, management, distribution, and portfolio management services and oversight of any portfolio sub-advisory services provided to the funds One of the services listed is the payment of annual trailing commissions to the dealer, including where the dealer is a discount broker, in connection with the distribution of the shares of the funds. ...
General Information Letter

18 October 2004 General Information Letter 46388 - GENERAL INFORMATION LETTER Fees for automated banking services (ATM)

Section 23 of Part V of Schedule VI to the ETA zero-rates a supply of an advisory, professional or consulting service made to a non-resident person, but not including a supply of (a) a service rendered to an individual in connection with criminal, civil or administrative litigation in Canada, other than a service rendered before the commencement of such litigation; (b) a service in respect of real property situated in Canada; (c) a service in respect of tangible personal property that is situated in Canada at the time the service is performed; or (d) a service of acting as an agent of the non-resident person or of arranging for, procuring or soliciting orders for supplies by or to the person. ...
GST/HST Interpretation

10 December 2007 GST/HST Interpretation 89629 - Registered Tour Operator

Underwriting: act as arranger and placement agent in connection with distribution of securities, lead manager of soliciting dealer/underwriting group (often right of first refusal, if accepted, governed by separate agreement with separate fees). 12. ...
GST/HST Interpretation

21 December 2007 GST/HST Interpretation 86844 - Tax Status of Sewer Services Supplied by a Private Developer

We were advised that in XXXXX approved a variance to the XXXXX Bylaw XXXXX in connection with the Subdivision acknowledging servicing from private sanitary sewer systems and to indicate that the XXXXX has no responsibility for a sewer system or to provide sewer services in the Subdivision. ...
GST/HST Interpretation

6 March 2008 GST/HST Interpretation 92711 - Application of GST/HST to Sweetened Baked Goods and Paragraph 97 of GST/HST Memoranda Series 4.3, Basic Groceries

These facts are determinative that the block fee is not dependent on any services actually being, or to be, provided to the patient- there may be no services, very few services, or there may be extensive services performed in connection with this fee. ...
GST/HST Interpretation

10 May 2022 GST/HST Interpretation 234662 - Ability for a joint venture operator to credit GST/HST new housing rebates to purchasers of residential condominium units

The definition of “commercial activity” in subsection 123(1) includes, in paragraph (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…”. ...
GST/HST Interpretation

29 August 1994 GST/HST Interpretation 1994-08-29[2] - Allowances Paid to Self-employed Staff

29 August 1994 GST/HST Interpretation 1994-08-29[2]- Allowances Paid to Self-employed Staff XXXXX August 29, 1994 XXXXX Subject: XXXXX This is further to your memorandum of December 17, 1993 to XXXXX at Headquarters, requesting a technical review of two contentious issues related to an audit performed on a GST registrant, XXXXX, in connection with the production of XXXXX[.] ...
GST/HST Interpretation

26 July 1995 GST/HST Interpretation 11725-1[1] - Agency Agreement for Medical Practitioners

In connection with this, a question as to who the employer is in this situation, has been raised. 2. ...
GST/HST Interpretation

30 June 1995 GST/HST Interpretation 11846-3[1] - Application of GST to Funding Received by the

"Commercial activity" of a person is defined in subsection 123(1) of the ETA as "(a) a business carried on by the person (other than a business carried on by an individual or a partnership, all of the members of which are individuals, without a reasonable expectation of profit), 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 by an individual or a partnership, all of the members of which are individuals, without a reasonable expectation of profit), 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;". ...

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