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Under the lease agreement, the lessees are required to defend, indemnify and hold harmless the lessor and the officers and employees of the lessor from and against any damage, loss, theft or destruction of any vehicle, and against all losses, liabilities, damages, injuries, claims, demands, costs and expenses of every kind and nature, whether or not covered by insurance, including legal fees and disbursements, arising out of and in connection with the use, condition or operation of vehicles during the lease term. 3. ...

27 July 2000 GST/HST Interpretation 25170- Application of the GST/HST to Marketing Services Unedited CRA Tags ETA 142(1)(g); ETA Sch VI, Part V, 7; ETA Sch VI, Part V, 8 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX XXXXX Case: HQR25170July 27, 2000 Subject: GST/HST INTERPRETATION XXXXX Dear XXXXX Thank you for your Memorandum of May 6, 1999, that you faxed to our XXXXX, in which you requested an interpretation in connection with the application of the Goods and Services Tax (GST), under the Excise Tax Act (the Act). ...

One of its customers in Holland, that acquired the services supplied by XXXXX in connection with designing and uploading its customer's website onto the Internet, is complaining that it should not be paying GST because of the tax treaty between Canada and Holland. ...

For the purposes of paragraph 23(c), our administrative position is that the service is in respect of tangible personal property if there is more than a mere indirect or incidental nexus or connection between the service and the underlying tangible personal property. ...

The agreement provided does not appear to make any connection between the CBA and the early payment discount. ...

The pertinent definitions in subsection 123(1) of the Excise Tax Act (ETA) in determining whether or not a taxable supply is being made are as follows: "taxable supply" means a supply that is made in the course of a commercial activity; "commercial activity" of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual a personal trust or a partnership, all of the members of which are individuals), 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 without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), 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 or in connection with the making of the supply; "business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever, whether the activity or undertaking is engaged in for profit, and any activity engaged in on a regular or continuous basis that involves the supply of property by way of lease, licence or similar arrangement, but does not include an office or employment; "office" has the meaning assigned by subsection 248(1) of the Income Tax Act (ITA) but does not include (a) the position of trustee in bankruptcy, (b) the position of receiver(including the position of a receiver within the meaning assigned by subsection 266(1), or (c) the position of trustee of a trust or personal representative of a deceased individual where the person who acts in that capacity is entitled to an amount for doing so that is included in computing, for the purposes of that Act,, the persons income or where the person is an individual, the person's income from a business; and "office" (subsection 248(1) of the ITA) means the position of an individual entitling the individual to a fixed or ascertainable stipend or remuneration and includes a judicial office, the office of a minister of the Crown, the office of a member of the Senate or House of Commons of Canada, a member of a legislative assembly or a member of a legislative council and any other office, the incumbent of which is elected by popular vote or is elected or appointed in a representative capacity and also includes the position of a corporation director, and "officer" means a person holding such an office. ...

14 July 2000 GST/HST Interpretation 13612- The Supply of Brochures and Catalogues Made to US Customers Unedited CRA Tags ETA 142(1)(a); ETA 142(1)(g); ETA 179(3) Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXXXXXXX 13612 XXXXXJuly 14, 2000 Subject: GST/HST INTERPRETATION The Supply of Brochures and Catalogues Made XXXXX to US Customers Dear XXXXX: Thank you for your letters of December 3, 1998 and January 12, 1999, and the additional information sent electronically to XXXXX, by XXXXX of your office, in connection with your request for a GST/HST ruling regarding the treatment of Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to certain scenarios as outlined below. ...

Commercial activity, as defined in subsection 123(1), includes in paragraph (c) of the definition, the making of a supply (other than an exempt supply) by a 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, is a commercial activity. ...

Therefore, it is recommended that the direct and indirect costs described be reviewed to determine if these costs (and to what extent) are in connection with the supply of the XXXXX administrative service to the investors. ...

In order for the exemption to apply, it must be evident that there is some connection between the supply of the instruction or tutoring in question, and the curriculum designated by a school authority. ...