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You had requested that our office issue advance rulings in connection with the subject transactions. ... May we suggest that you read the section in connection with this letter. ... In such cases, there would be no GST/HST payable on the self-supply, as provided for by subsection 336(1) in connection with the transfer of real property before 1991. ...

. • ABC will provide services in connection to the closing of loans by the Lenders, including advising the Manufacturer on the criteria set by the Lender for adjudicating loans and any changes thereto. ... ABC will provide training to the Dealer in connection to the use of the Website. • Once the loan application has been submitted, the Dealer will be advised online whether the application has been approved, declined or submitted for management review. ... For the services provided by ABC in connection with the Finance Program, ABC charges a lump sum fee to the Vendor for the implementation services described above, as well as charges a transaction fee for each transaction. ...

The Manager will provide management services required in connection with the JV lands and project. e. ... The Manager has the power and authority to act and take the steps that are necessary in connection with the performance of the services, including entering into contracts and commitments on behalf of the JV, without further approval of the Co-Owners, subject to certain limitations which may include: i. ... The Co-Owners will indemnify the Manager for any liabilities or claims it may incur in connection with the performance of the management services, other than claims resulting from gross negligence or willful misconduct of the Manager or a breach by the Manager of the terms of the management contract. v. ...

As indicated in GST/HST Technical Information Bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province (available on the CRA web site at http://www.cra-arc.gc.ca/E/pub/gm/b-103/b-103-e.pdf), whether a service is considered to be in relation to TPP depends on whether there is a direct connection between the service and the TPP taking into account the objective of the service and the particular circumstances of each case. There are several guidelines that are used to determine whether there is a direct connection between a service and TPP. ... If something else comes between the service and the TPP, the connection will not be considered to be direct. ...

We conclude the legislative phrases should be applied in the widest possible context, subject to there existing a causal connection between the thing being seized and the contravention. ... Somewhat less information is available on the phrase "by means of", however in a criminal case heard by the Quebec Court of Appeal, it stated that, with reference to section 68 of the Criminal Code, the phrase "by means of" necessarily implies a causal connection between the death and the alleged unlawful act. ... (emphasis added) We conclude that where the seizing officer determines, or "reasonably believes", that there is a connection between a 'thing' and a contravention of the Act, the 'thing' is subject to seizure pursuant to the provisions of paragraph 260(2)(f). ...

Paragraph 4 of Interpretation Bulletin IT-386R indicates that there is a "mirror-image test" to determine whether an amount which a taxpayer has received in connection with a business as a result of the disposition of property, is proceeds from the disposition of eligible capital property. In effect, a taxpayer disposing of property in connection with a business "looks in the mirror" to see whether, if the taxpayer were instead purchasing the property, its cost would qualify as an eligible capital expenditure of the taxpayer for the same business. ... Therefore, it is our view that the definition of capital property in subsection 123(1) of the ETA also does not include eligible capital property, because of the close connection between the Income Tax Act definition of capital property and the definition in subsection 123(1) of the ETA. ...

In this regard, we have enclosed herewith for your perusal a revised draft of the actual entries that will be used by XXXXX in connection with the accelerated payments program and would ask you to revise the GST Application Ruling accordingly; 4. ... You will note from your review of the enclosed revised accounting entries to be used by XXXXX in connection with the accelerated payments program that the entries now reflect a GST included amount. Would you please confirm that the accounting entries now proposed by XXXXX in connection with the accelerated payment program will not affect the ruling given in the GST Application Ruling dated December 5, 1995. ...

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 10. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 22. ...

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 4. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 8. ...

Under subsection 3(1) of the MMPR a person listed in subsection 3(2) may possess dried marihuana if the dried marihuana is obtained (a) in accordance with the MMPR; (b) in the course of activities performed in connection with the enforcement or administration of any Act or its regulations; (c) from a person who is exempt under section 56 of the CDSA from the application of subsection 5(1) of the CDSA with respect to the dried marihuana or cannabis; or (d) in the case referred to in subparagraph 3(2)(a)(iii) of the MMPR, under subsection 65(2.1) of the NCR. 10. ... In particular, under subsection 12(4) of the MMPR a licensed producer may (a) sell or provide dried marihuana to (i) a client of that producer or an individual who is responsible for the client; (ii) a hospital employee, if the possession of the dried marihuana is for the purposes of and in connection with their employment; or (iii) a person to whom an exemption relating to the dried marihuana has been granted under section 56 of the CDSA. ... In particular, under subsection 22(4) of the ACMPR a licensed producer may (a) sell or provide fresh or dried marihuana or cannabis oil to (i) a client of that producer or an individual who is responsible for the client, (ii) a hospital employee, if the possession of the substance is for the purposes of and in connection with their employment, or (iii) a person to whom an exemption relating to the substance has been granted under section 56 of the CDSA; and (b) ship fresh or dried marihuana or cannabis oil to a health care practitioner in the case referred to in subparagraph 130(1)(f)(iii) of the ACMPR. 22. ...