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GST/HST Interpretation
12 September 2002 GST/HST Interpretation 33056 - Internet Access
None of the facilities made available by the Company, or any part thereof, that enable connection to the Internet, are located in Canada (e.g., a server located in Canada would not be made available by the Company under any circumstances to the non-resident to enable connection to the Internet). ... A part of the facilities made available by the Company that enable connection to the Internet are located in Canada. ... Scenario 1 In this scenario, no part of the telecommunications facilities made available by the Company and that enables connection to the Internet is located in Canada. ...
GST/HST Interpretation
3 June 2009 GST/HST Interpretation 105881 - FCTIP - Exhibitor's Rebates
Exhibitor 1 asked the Company to file a rebate claim on its behalf for the GST that XXXXX paid on the hotel accommodation he purchased in connection with his stay. ... Generally, short-term accommodation supplied by a hotel to an exhibitor would be regarded as a related convention supply where the exhibitor acquired the accommodation and used it exclusively in connection with a convention. ... An employer that reimburses an employee for expenses incurred in connection with the employer's activities may claim an input tax credit or a rebate with respect to the GST/HST that it is considered under subsection 175(1) to have paid. ...
GST/HST Interpretation
8 August 2014 GST/HST Interpretation 157867 - Commission revenue earned by automobile dealers
The Dealer shall be responsible for and shall pay all taxes, including without limitation, sales and excise taxes, which may be owing in connection with the assignment of the Contracts and in connection with all amounts, including fees paid by Lender2 to the Dealer in connection with Agreement2. ... The Dealer shall be responsible for and shall pay all taxes, including without limitation, sales and excise taxes, which may be owing in connection with the assignment of the Contracts and in connection with all amounts, including fees paid by Lender3 to the Dealer in connection with Agreement3. ... INTERPRETATION REQUESTED You would like to know if commission revenues earned by the Dealers with respect to the assignment of Conditional Sales Contracts and to services provided to Lenders in connection with loans supplied by the Lenders are consideration for the supply of exempt financial services. ...
GST/HST Interpretation
6 July 1998 GST/HST Interpretation HQR0001194 - Services Supplied to a Non-Resident Trust
There must be more than a mere indirect or incidental connection between a service and the underlying real property before the supply of the service will be excluded from zero-rating under Schedule VI, Part V, section 7. In the scenario described above, there is a connection between the Portfolio Servicing and real property, but the connection is indirect. ...
GST/HST Interpretation
23 September 2002 GST/HST Interpretation 42342 - Internet Access
From your facsimile and our telephone conversations, our understanding of the situation is as follows: • An Internet Service Provider (ISP) located in Canada supplies Internet access to a Canadian company's subsidiary located in the U.S; • The Canadian company's subsidiary in the U.S. is not registered for GST/HST purposes; • The ISP bills the Canadian company in U.S. dollars for the supply of the Internet access provided by the ISP to the subsidiary; and • The server that enables connection to the Internet is located in the U.S. ... Based on the information provided and assuming that, as well as the server, all other facilities, or any part thereof, that are used or are capable of being used to enable connection to the Internet are located outside Canada, the Internet access supplied by the ISP to the Canadian company's subsidiary is not deemed to be a supply made in Canada pursuant to subparagraph 142.1(2)(a) of the Act. ... It is important to note that this applies only where none of the ISP's facilities, or any part thereof, that are located in Canada are used to enable the connection to the Internet under any circumstances. ...
GST/HST Interpretation
7 April 2014 GST/HST Interpretation 139981r - Application of the GST/HST to the distribution of private placements by investment dealers
The obligation to pay the commission will arise at the closing time. * The Issuer and Agents acknowledge that the Agents are acting solely as agents in connection with the Offering, and that no Agent will assume any advisory responsibility in favour of the Company in connection with the contemplated 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. ... Since each element is therefore an integral part of the Distribution Service being performed, [the Dealer], as the Broker, Finder or Agent, provides a single supply to the Issuer, Company or Corporation in connection with Agreements 1, 2,3, the [A] Agreement, [B] Agreement, and [C] Agency Agreement. ...
GST/HST Interpretation
15 June 2000 GST/HST Interpretation 31364 - Application of GST to Billings to Non-Residents
Interpretation Requested The supply of legal services, made to the non-resident insurance company, is zero-rated pursuant to section 23 of Part V of Schedule VI to the Excise Tax Act ("the Act"), providing the supply does not include a supply of a service rendered to an individual in connection with criminal, civil or administrative litigation in Canada. ... Rationale Although the supply of legal services is made to the non-resident insurance company, the supply is actually being rendered to the client, who is an individual, in connection with litigation in Canada. ...
GST/HST Interpretation
17 May 2012 GST/HST Interpretation 62492 - Application of the GST/HST to point-of-sale terminal fees
[Agreement 4] The Acquirer is identified under [Agreement 4] as a Connection Service Provider and Settlement Agent for the ISO. As a Connection Service Provider, the Acquirer provides connection to the Interac network for the purpose of processing Interac Direct Payment transactions. ... The ISO engages the Acquirer to perform connection services to the Interac network in order to give card holders on-line, real time access to their bank accounts in order to obtain goods and services from merchants. ...
GST/HST Interpretation
21 July 2009 GST/HST Interpretation 85214 - Tax Status of Supplies by an Insurer
Also, anything done by the insurer in the course of, or in connection with, the making of the supply and not in connection with the transfer of the property shall be deemed to have been done in the course of the commercial activity. ... ITC entitlement with respect to sales of salvaged property: Subsection 184(2) provides that anything done by the insurer in the course of, or in connection with, the making of the supply and not in connection with the transfer of the property shall be deemed to have been done in the course of the commercial activity of making the supply, unless subsections 184(3) to 184(5) applied at an earlier time in respect of the use of the property by the insurer. ... However, any GST/HST paid or payable on property and services to the extent that the property and services are for consumption, use or supply in the course of or in connection with the transfer of the vehicle from the insured to XXXXX is not eligible for ITCs. ...
GST/HST Interpretation
19 March 2012 GST/HST Interpretation 139282 - GST/HST Interpretation - Place of Supply of Services
An address of the recipient obtained by a supplier will only be relevant for purposes of subsection 13(1) if it is obtained in the ordinary course of the supplier's business practices in connection with the supply. ... An address of the recipient obtained by a supplier in the ordinary course of business could therefore include: an address of the recipient from which the supplier is hired in connection with a supply pursuant to an agreement for the supply (the "contracting address"); an address of the recipient that the supplier deals with in connection with a supply; or a billing address of the recipient in connection with a supply. ...