Search - connection

You state that other expenses incurred (such as legal fees for professional services in connection with the lease, travel expenses between her residence and the Property to check up on the Property, etc.) were not reported for income tax purposes because your client was of the view that she was not operating a business and, if these expenses had been reported, they would have had little impact on her personal tax return as she had no meaningful sources of income. ... A fee of $[…] for professional services rendered in connection with this HST matter was incurred by your client in [yyyy]. * The Property was capital property of your client and the co-owner. ...

., purchases of goods and services, credit card fees, etc.) made in connection with the corporate card issued to the card member; to read: 1. there must be one or more written agreements stating that the card member is solely or jointly and severally liable with the company for the payment of all charges (e.g., purchases of goods and services, credit card fees, etc.) made in connection with the corporate card issued to the card member. ...

In consideration of the Assumption of the Bridge Liability by XXXXX agreed to transfer lands to XXXXX to meet the XXXXX needs in connection with the reparation of the Bridges and related work. ... Interests to be conveyed to XXXXX agreed to make a contribution of XXXXX to meet the XXXXX needs in connection with the Bridge Liability. ...

The following guidelines will be applied by the Department to aid in the determination of whether the connection between the service and the TPP is sufficiently direct for the service to be "in respect of" the property for purposes of paragraph 7(e) of Part V of Schedule VI to the ETA: •   Was the service designed, developed or undertaken to fulfill or serve a particular need or requirement arising from or relating to the property? ... If some object comes between the service and the property, the connection becomes increasingly remote. ...

The Corporation of the Town XXXXX entered into a cost sharing agreement XXXXX XXXXX XXXXX in order to facilitate the future connection of XXXXX two Town roads. 2. ... Administration and Overhead XXXXX •   Upon award of the contract, XXXXX will provide the Town with the recommended bid prices for the Town's work and a summary of the submitted tenders XXXXX, and the Town shall accept its actual share in writing prior to commencement of construction. •   Prior to commencement of construction, the Town shall obtain all federal, provincial and other necessary approvals and clearances required for the Town's work. •   The Town shall indemnify and save harmless XXXXX from and against any claim, action, cause of action or liability for loss, damage, accident or injury in any manner arising due to, out of, from or in connection with the Town's design for the Town's work. •   The Town shall be responsible for any increased expenses of the Town's work incurred by XXXXX, including applicable surcharges and tax, which are attributed to any request of the Town to delete or add work, delays for which XXXXX is not responsible, or errors and/or discrepancies made in the design or contract documentation prepared by the Town. •   From time to time, XXXXX shall invoice the Town for the Town's share of the unpaid actual cost for the Town's work completed, including applicable surcharges. ...

As requested, we acknowledge that the Canada Customs and Revenue Agency ("CCRA") issued two GST/HST Application Ruling/Interpretation letters dated December 8, 1997 and September 17, 1999 ("the Rulings") respectively, in connection with XXXXX for the provision of "GST/HST-free" shopping in Canada for non-resident visitors XXXXX[.] ...

DATE May 17, 2012 FROM Paul Lafond Financial Institutions Unit Financial Institutions and Real Property Division TO [Addressee] FILE 97556 SUBJECT : GST/HST Interpretation- Referral services associated to point-of-sale processing services Further to […][your inquiry], we are writing in response to your concerns on the application of the GST/HST to supplies of referral services provided by […](Supplier) in connection with point-of-sale (POS) debit and credit card processing services (Processing Services). ... Member for the provision of the Processing Services in connection to the debit and credit card transactions. ... 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. ...

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 website 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 real property depends on whether there is a direct connection between 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 real property. ... If something else comes between the service and the property, the connection will not be considered to be direct. ...

TO: XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX CASE NUMBER: 102898 DATE: May 12, 2008 SUBJECT:_GST/HST Interpretation GST Treatment of Assignment of Lease and Related Payments This memorandum is in response to your XXXXX to Dawn Weisberg XXXXX, wherein you requested an opinion as to the application of the GST to payments made in connection with assignments of leases to XXXXX. ... Authorization by XXXXX to XXXXX to wire funds in connection with an advance relating to the assignment of a lease with XXXXX dated XXXXX; 2. ... These documents purport to re-characterize the assignment as follows: (i) Advance: There is an advance by XXXXX to XXXXX; repayments of the advance are drawn from XXXXX account concurrent with lease payment due dates; (ii) Assignment: There is an assignment by XXXXX to XXXXX of lease-related assets to secure repayment of the advance; (iii) Possible Administrative Services: XXXXX is to continue to collect lease payments and taxes from XXXXX XXXXX; XXXXX is to be responsible for expenses in connection with admin services relating to the administration of the leases. ...

As set out in GST/HST policy statement P-169R (P-169R Meaning of "in respect of real property situated in Canada" and "in respect of tangible personal property that is situated in Canada at the time the service is performed", for purposes of Schedule VI, Part V, sections 7 and 23 to the Excise Tax Act), and GST/HST Memorandum Series, Section 4.5.3, Exports- Services and Intellectual Property, the CRA's position is that there must be more than a mere indirect or incidental connection between a service and the underlying tangible personal property before the supply of the service will be considered to be "in respect of" the property and consequently excluded from zero-rating. ... The following guidelines will be applied to determine whether the connection between the service and the tangible personal property is sufficiently direct for the service to be "in respect of" the property for purposes of paragraph 7(e) of Part V of Schedule VI to the Act: (a) Whether the service is designed, developed or undertaken to fulfil or serve a particular need or requirement arising from or relating to the tangible personal property, which involves determining the purpose or objective of the service. ... If some object comes between the service and the property, the connection becomes increasingly remote. ...