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The Master Service Agreement states that XXXXX will provide the following services to XXXXX in connection with the administration of Canadian dollar swap agreements with third parties: (i) negotiation and preparation of appropriate documentation, including master agreements and other required documentation with third parties; and (ii) performance of back office support functions in connection with transactions entered into with third parties, including confirmations, periodic resets, booking transactions on the XXXXX system, and performing account and position reconciliation. ...

On the question of the XXXXX acting as a conduit in connection with the billing by the XXXXX of disbursements, the billing of such disbursements would flow through from the XXXXX to XXXXX where XXXXX is the recipient of the supply to which the disbursements relate. ... You also seek clarification in connection with the term "subcontracts" used in the fourth paragraph, under Interpretation Given, as the term applies to XXXXX. ...

It describes the XXXXX as being comprised of the following: •   A water supply system consisting of a well supply, ground storage reservoir, pumping station, a distribution system, hydrants, and water service connections; •   A sewage system consisting of building sewer connections, sanitary sewers, sewage pumping station, force mains, sewage treatment plant, storage pond and outfall sewer; •   A storm drainage system consisting of catch basins, manholes, pipes, ditches, culverts and retention system; •   An irrigation system as applicable; •   Roadways, street lighting and walkways; •   Hydro; •   Private garbage pick-up and disposal; •   Community Centre; and •   Other necessary servicing. ...

For checked items, this usually means that the item is given a baggage slip indicating the same flight number, connections and destination airport of the passenger. ... However, paragraph 4(a) of Part VII of Schedule VI to the ETA zero-rates the supply of a service of transporting an individual's baggage where the supply is made by a person in connection with the supply by that person of a zero-rated passenger transportation service. ... The use of XXXXX registration number in connection with the supply of passenger transportation services made by XXXXX is only acceptable if XXXXX acts as agent in causing or facilitating the making of the supply by XXXXX. ...

Co owns all rights, title and interests, including intellectual property rights in and to: (a) the Portals, including all content thereat, excluding any content provided by the Lenders to X Co. for use in connection with the Supply; (b) any domain names registered by X Co. in connection with the Portals and/or the Supply; (c) all trademarks, logos or other identifying names or marks used in connection with the Portals, except for the trademarks and logos owned by the Lenders; (d) the Software and all associated documentation, including training and user documentation provided by X Co. for use in connection with the Supply and the business model related to the provision of the Supply; and (e) any interface, including data maps, constructed in order for the Portals to access the Lenders' computer systems. ...

XXXXX has no connection to the software system and the only reason it enters into the service agreement is because of XXXXX prior relationship with XXXXX. 7. ...

As we have discussed, in order for us to comment as to whether or not an organization's activities in connection with a particular housing project are qualifying activities for purposes of the municipal rebate, we require supporting documentation such as signed and dated copies of applicable operating or other funding agreements, including all schedules and appendices, as well as an explanation of the nature of the housing and how rent-geared-to-income is calculated. ...

A "freight transportation service" as defined in subsection 1(1) of Part VII of Schedule VI to the Act means: "a particular service of transporting tangible personal property and, for greater certainty, includes (a) a service of delivering mail, and (b) any other property or service supplied to the recipient of the particular service by the person who supplies the particular service, where the other property or service is part of or incidental to the particular service, whether there is a separate charge for the other property or service, but does not include a service provided by the supplier of a passenger transportation service of transporting an individual's baggage in connection with the passenger transportation service. ...

A number of services are specifically excluded from this section, as follows: (a) a service rendered to an individual in connection with criminal, civil or administrative litigation in Canada, other than a service rendered before the commencement of such litigation; (b) a service in respect of real property situated in Canada; (c) a service in respect of tangible personal property that is situated in Canada at the time the service is performed; or (d) a service of acting as an agent of the person. ...

Our conclusion is based on the fact that the agreement includes provisions that are indicative of the transfer being done for the purposes of securing a loan, such as the following in Schedule A: "the assignment of the collateral by the Assignor is in consideration of the advance by the Assignee, of the principal amount... and a further amount of XXXXX... due and payable on the 1rst day of April 1996" the following in clause 8, which provides that the Assignee will: "apply any Lease Payments or any other payments received by it (from the Lessee, the Assignor or otherwise) first to the payment of accrued interest, then to the payment of other amounts then due and then to the outstanding principal owing the Assignee, and to pay the excess to the Assignor". the following in clause 4 which provides that upon payment in full of the Lease Payments, the Assignee shall: "cancel this Agreement and deliver all such cancelled documents to the Assignor... and deliver to the Assignor such discharges and other documents as the Assignor may reasonably require to discharge this Agreement and any security registration statements filed in connection therewith" and the provisions in subclauses 17(2) and ss. 17(3) which provide that at the expiry of the term of the lease, title to the property will be reconveyed to the Assignor in full consideration for and satisfaction of the XXXXX[.] ...