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XXXXX[.] 6. the card member is liable to XXXXX for all charges made in connection with their XXXXX card as stated in XXXXX[.] ... It is stated in your letter that XXXXX cannot distinguish personal charges from business charges on the XXXXX card statement; XXXXX 9. the terms and conditions of XXXXX are very similar to those of XXXXX in that the card members are liable for all charges made in connection with the XXXXX cards issued to them (i.e., provided under XXXXX References in the agreement are also made to the limited role of the company; 10. the liability of the card members is also pronounced in the XXXXX which says that: "... the undersigned individual applicant agrees to be solely liable for all charges incurred with the Card as provided in the terms and conditions of XXXXX[".] 11. as for the company's limited liability, XXXXX states under XXXXX section that: "... XXXXX will send monthly statements of charges to each XXXXX Cardmember, who will be solely responsible for all Charges made in connection with XXXXX Card issued to the XXXXX Cardmember. ...

You had requested that our office issue advance rulings in connection with the subject transactions. ... May we suggest that you read the section in connection with this letter. ... In such cases, there would be no GST/HST payable on the self-supply, as provided for by subsection 336(1) in connection with the transfer of real property before 1991. ...

. • ABC will provide services in connection to the closing of loans by the Lenders, including advising the Manufacturer on the criteria set by the Lender for adjudicating loans and any changes thereto. ... ABC will provide training to the Dealer in connection to the use of the Website. • Once the loan application has been submitted, the Dealer will be advised online whether the application has been approved, declined or submitted for management review. ... For the services provided by ABC in connection with the Finance Program, ABC charges a lump sum fee to the Vendor for the implementation services described above, as well as charges a transaction fee for each transaction. ...

The Manager will provide management services required in connection with the JV lands and project. e. ... The Manager has the power and authority to act and take the steps that are necessary in connection with the performance of the services, including entering into contracts and commitments on behalf of the JV, without further approval of the Co-Owners, subject to certain limitations which may include: i. ... The Co-Owners will indemnify the Manager for any liabilities or claims it may incur in connection with the performance of the management services, other than claims resulting from gross negligence or willful misconduct of the Manager or a breach by the Manager of the terms of the management contract. v. ...

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 web site 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 TPP depends on whether there is a direct connection between the service and the TPP taking into account the objective of 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 TPP. ... If something else comes between the service and the TPP, the connection will not be considered to be direct. ...

Paragraph 4 of Interpretation Bulletin IT-386R indicates that there is a "mirror-image test" to determine whether an amount which a taxpayer has received in connection with a business as a result of the disposition of property, is proceeds from the disposition of eligible capital property. In effect, a taxpayer disposing of property in connection with a business "looks in the mirror" to see whether, if the taxpayer were instead purchasing the property, its cost would qualify as an eligible capital expenditure of the taxpayer for the same business. ... Therefore, it is our view that the definition of capital property in subsection 123(1) of the ETA also does not include eligible capital property, because of the close connection between the Income Tax Act definition of capital property and the definition in subsection 123(1) of the ETA. ...

In this regard, we have enclosed herewith for your perusal a revised draft of the actual entries that will be used by XXXXX in connection with the accelerated payments program and would ask you to revise the GST Application Ruling accordingly; 4. ... You will note from your review of the enclosed revised accounting entries to be used by XXXXX in connection with the accelerated payments program that the entries now reflect a GST included amount. Would you please confirm that the accounting entries now proposed by XXXXX in connection with the accelerated payment program will not affect the ruling given in the GST Application Ruling dated December 5, 1995. ...

., 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. ...

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. ...

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[.] ...