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GST/HST Interpretation

18 May 2000 GST/HST Interpretation 25716 - Application of the GST/HST to Programs Supplied to Non-resident, Non-registered International Tour Operators

For administrative purposes, when a transfer to another conveyance is required in order to complete the continuous journey, a period of 24 hours will be considered reasonable within which to make this connection. If a longer stop is required, it is the responsibility of the supplier or travel agency to demonstrate that the length of the stop is for connection purposes only; 4. the continuous journey contains a qualifying international origin, destination or stopover; and 5. the supplier or travel agent must be able to demonstrate to the Minister that the conditions for treating a domestic ticket or voucher as part of a continuous international journey have been met. ... The domestic ground transportation in the two itineraries would be considered part of a continuous journey including the international air transportation because the international air transportation and domestic ground transportation are each issued on a single ticket and there are no stopovers between the connections of the ground transportation to the inbound and outbound air transportation. ...
GST/HST Interpretation

12 April 2000 GST/HST Interpretation 8394/HQR0002000 - Sale-leaseback Arrangements - Entitlements to ITCs

The definition of "commercial activity" in ETA paragraph 123(1)(c) include: "the making of a supply (other than an exempt supply) by the person of real property, including anything done by the person in the course of or in connection with the making of the supply. ... With regards to the construction of the Facility subsequently sold to the Purchaser/lessor, to conclude that it is a commercial activity of the Registrant, it must have been undertaken "in the course of or in connection with the making of the supply". I agree with your position that there is a direct connection between the construction of the Facility and its sale, and consequently, the construction of the Facility was undertaken in the course of or in connection with the supply of the Facility to the Purchaser/lessor. 2) Yes, it is the Canada Customs & Revenue Agency's position on sale-leaseback transactions that one must look to the first-order supply, not the ultimate intended use, for purposes of determining ITC entitlement. ...
GST/HST Interpretation

12 February 1999 GST/HST Interpretation HQR0001551 - Travel Allowances - Section 174 of the Excise Tax Act (ETA)

Pursuant to subparagraph 6(1)(b)(x) of the ITA, for the purposes of subparagraphs 6(1)(b)(v), (vi), and (vii.1) of the ITA, any allowance for the use of a motor vehicle will be considered "reasonable" only if it is based on the number of kilometres for which the vehicle is used in connection with the employer's activities. You stated that in your client's situation, allowances were not paid to the employees based solely on the number of kilometres for which the vehicles were used in connection with the employer's activities. ... As well, there would be no input tax credit entitlement with respect to an allowance paid to an employee for the use of a motor vehicle which was not based solely on the number of kilometres for which the vehicle was used in connection with the employer's activities. ...
GST/HST Interpretation

27 May 2016 GST/HST Interpretation 130865 - Permit Fees and Municipal Development Charges

For example, in some situations the regional municipality is the only level that can approve water connections. ... A number of steps are required in connection with the issuance of a permit to the land owner. ... The statutory authority under which the fees are charged by the regional municipality may be of assistance in characterizing the supply made in connection with that fee. ...
GST/HST Interpretation

1 August 1994 GST/HST Interpretation 1994-08-01 - Collection of GST on Duties Under the Special Import Measures Act

As long as there was a sufficient connection between the deemed importer and the transaction of importing the goods, then the deemed importer could be viewed as liable for duties under the Customs Act and therefore also liable for payment of GST. Agency relationships and certain contractual obligations would be examples of evidence of this connection. 2. ... For this reason, caution should be exercised in those rare instances of convoluted transactions in which the deemed importer appears to have no direct connection with the act of importing. ...
GST/HST Interpretation

13 December 2000 GST/HST Interpretation 31635 - ITC Eligibility of Costs Relating to Enhancing Shareholder Value

In XXXXX, XXXXX entered into a contract with XXXXX was to provide services as a financial advisor in connection with the Potential Transaction. ... The letter explains that XXXXX was engaged to act as financial advisor to the Board and Special Committee in connection with the Potential Transaction. ... XXXXX was engaged as a financial advisor in connection with the Potential Transaction. ...
GST/HST Interpretation

28 April 2000 GST/HST Interpretation 30301 - The Zero-Rating of Training Services Supplied by

28 April 2000 GST/HST Interpretation 30301- The Zero-Rating of Training Services Supplied by Unedited CRA Tags ETA Sch V, Part III, 8; ETA Sch VI, Part V, 18; GST/HST Policy Statement P-229, Definition of "Vocational School" in Section 1 of Part III of Schedule V to the Excise Tax Act; GST/HST Policy Statement P-231, Courses That Qualify for Exemption Pursuant to Section 8 of Part III of Schedule V to the Excise Tax Act XXXXX XXXXX XXXXX XXXXXAttention: XXXXX Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5Case: HQR30301April 28, 2000 Subject: GST/HST INTERPRETATION The Zero-Rating of Training Services Supplied by XXXXX Dear XXXXX Thank you for your letter of February 24, 2000 in which you request two separate interpretations in connection with the application of section 169 and section 18 of Part V of Schedule VI to the Excise Tax Act (the Act), in regards to the training services supplied by XXXXX a GST/HST registrant, XXXXX XXXXX, an unregistered non-resident. ... As mentioned previously, where XXXXX acquires goods and services for use in connection with a zero-rated supply of training services, such acquisitions would generally be viewed as being acquired in the course of XXXXX commercial activities. Accordingly, XXXXX would be eligible for input tax credits, in connection with those goods and services acquired for consumption, use or supply in the course of providing a supply of training services, where the supply is zero-rated under section 18 of Part V of Schedule VI to the Act. ...
GST/HST Interpretation

18 August 2000 GST/HST Interpretation 31463 - Supply of Switching Services to ABM Owner/Operators

Fee for Dial-up ABM connection and limited monitoring — Taxable XXXXX will charge a monthly fee for each Dial-up ABM connected to the XXXXX. ... Dial-up ABMs will not be monitored by XXXXX, as defined in XXXXX above, however, XXXXX will provide limited monitoring of the connection in the XXXXX. ... Network Connection Setup — Taxable This fee is charged for connecting the client's ABMs to client-selected Networks (Interac and/or Cirrus). ...
GST/HST Interpretation

8 March 2007 GST/HST Interpretation 86030 - Lease agreement entered into prior to March 10, 2004

XXXXX the Agreement provides that the employer shall pay to the employee's lawyer XXXXX on account of legal costs incurred in connection with the litigation and settlement of the matter. 6. The employee agreed in the Agreement to indemnify and save the employer harmless to any claims, charges or demands properly exigible which might be made upon it in respect of obligations in connection with this settlement to the Income Tax Act, the Employment Insurance Act, the Canada Pension Plan, or by any duly recognized federal or provincial taxing authorities in respect of income tax and/or payroll deductions previously withheld, including any legal fees and disbursements incurred in the defence of such claims. 7. ...
GST/HST Interpretation

26 July 2000 GST/HST Interpretation 25666 - Website Maintenance Contract

26 July 2000 GST/HST Interpretation 25666- Website Maintenance Contract Unedited CRA Tags ETA 142; ETA Sch VI, Part V, 7 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX Case: HQR25666July 26, 2000 Subject: GST/HST INTERPRETATION Website Maintenance Contract Dear XXXXX: Thank you for your letter of January 4, 2000 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to your particular situation in connection with the website maintenance contract you have with XXXXX). ... Interpretation Given According to the above information, it appears that the agreement between you and the unregistered non-resident provides, in substance, for the supply of a maintenance service in connection with your customer's website (i.e., a programming service), that is considered to be in respect of intangible personal property. ...

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