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Pursuant to the LPA, the Investor became a limited partner in the Non-resident Partnership and, in connection therewith, the Investor made an initial Capital Contribution of money to the Non-resident Partnership (the “Initial Investment”). 10. ...

"Commercial activity" is defined in subsection 123(1) of the ETA as "(a) a business carried on by the person (other than a business carried on by an individual or a partnership, all of the members of which are individuals without a reasonable expectation of profit), 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 by an individual or a partnership, all of the members of which are individuals, without a reasonable expectation of profit), 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 of or in connection with the making of the supply... ...

It should be noted that effective January 1, 2000, the service made by a supplier of a zero-rated passenger transportation service of supervising an unaccompanied child in connection with the passenger transportation service [xxxii] 24.  ... Place of supply of services relating to a passenger transportation service Though not specifically raised, we would like to mention that for HST purposes, a legislative change that became effective January 1, 2000, results in the supply made by a supplier of a passenger transportation service of supervising an unaccompanied child in connection with that service as being made in the same province in which the passenger transportation service is considered supplied [xlvii] 39.  ...