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GST/HST Ruling

27 March 1998 GST/HST Ruling HQR0000937 - Application of the GST/HST to the Subcontract for Fabrication and Testing of an Enhanced Ignition System

For purposes of paragraph 23(c) of Part V of Schedule VI to the ETA, The Department's administrative position as explained in our Policy Paper P-169, copy enclosed, is that there must be more than a mere indirect or incidental nexus or connection between a service and the underlying tangible personal property, before the supply of the service will be excluded from zero-rating. ... The following guidelines will be applied by the Department to aid in the determination of whether the connection between the service and the tangible personal property is sufficiently direct for the service to be "in respect of" the property for purposes of paragraph 23(c) of Part V of Schedule VI to the ETA: a) 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. ...
GST/HST Ruling

4 February 2009 GST/HST Ruling 93552 - Instruction in Languages

Although the School's curriculum is modified to fit time and student-level constraints not faced by the school authority, when examined together, the School's curriculum has a direct connection with the XXXXX Language Arts Kindergarten to Grade 9 curriculum designated by XXXXX listed on the XXXXX website. ...
GST/HST Ruling

1 May 1995 GST/HST Ruling 11590-5, 11595-3, 11783-2 - Status of Production Financing

The fact that XXXXX is 100 percent funded by the provincial government entitles it to claim a 50 percent rebate for any GST paid on purchases made in connection with its exempt activities. ...
GST/HST Ruling

1 July 1998 GST/HST Ruling HQR0000902[2] - Basic Groceries

You confirmed that, to the best of your knowledge, none of the issues described herein is being considered by a Revenue Canada Office in connection with a GST/HST return already filed and none of the issues are under objection or appeal. ...
GST/HST Ruling

1 September 1999 GST/HST Ruling HQR0001873 - The Zero-Rating of Civil Litigation Services

Although you are requesting an interpretation, your question is in connection with the application of a specific provision of the legislation, as it relates to a clearly defined fact situation. ...
GST/HST Ruling

24 December 1998 GST/HST Ruling HQR0001285 - Supplies to a Non-resident Film Company

The Producer is an independent contractor in connection with the provision of the Production Services. ...
GST/HST Ruling

30 March 2001 GST/HST Ruling 33775 - Rebate for Printed Books

" A "specified person" in this connection includes a charity that operates a "public lending library. ...
GST/HST Ruling

29 May 2002 GST/HST Ruling 39826 - Supply of Promotional CD with

XXXXX is in the business of selling food for human consumption, and does not ordinarily sell or distribute non-food items, except in connection with promotional activities. ...
GST/HST Ruling

12 April 2019 GST/HST Ruling 190982 - Supply of various feeding utensils and other gripping devices

As a result, in the context of section 38 of Part II of Schedule VI, the CRA considers that a feeding utensil refers to a gripping device that is specially designed for the use described in this section, and as such, must have a connection with gripping as well as with feeding. Based on the CRA’s position outlined above, the supply of the following products are feeding utensils specially designed for use by an individual with impaired use of hands or other similar disability and are zero-rated under section 38 of Part II of Schedule VI: Liftware Steady- […][Item #] Angled / Contoured Cutlery- […][Item #s] Weighted utensils- […][Item #s] In contrast, although the following products are feeding utensils, it is the CRA’s view that these products do not have design features that demonstrate a connection with gripping, regardless of whether the product has suction cups or non-skid pads: Knork®- […][Item #] Scooper Bowl- […][Item #] Scoop Dish- […][Item #] Soup/Cereal Bowl- […][Item #] Round Up Plate- […][Item #] Inner Lip Plate- […][Item #s] […]Plate- […][Item #] In addition, the following feeding utensils, although they may have design features that allow for easy gripping, are not specially designed for use by an individual with impaired use of hands or other similar disability: HALO™ Cup- […][Item #] […]Mug- […][Item #] Soft Nosey Cup- […][Item #] […][X Cup]- […][Item #s] Therefore, for the last eleven items listed above the requirements in section 38 of Part II of Schedule VI have not been met. ...
GST/HST Ruling

29 January 2015 GST/HST Ruling 159222 - GST/HST on fees relating to a loan

. * Other: All legal fees in connection with this agreement are for the account of [BCo]. ... On [mm/dd/yyyy], [ACo], [CCo], and [BCo] entered into an Assignment Agreement (Assignment Agreement) which contained the following provisions: * Pursuant to the Term Sheet, [ACo] agrees to make certain loans and advances to [BCo], subject to the terms and conditions of the Term Sheet (the “Credit Facilities”); * Pursuant to terms of the Term Sheet, [ACo] has the discretion as to the entity that will enter into the loan arrangements with [BCo] and fund the advances made to [BCo] pursuant to the Term Sheet; * [ACo] has designated [CCo] as the Lender under the Term Sheet; * For consideration of $[…] paid by [CCo] to [ACo], [ACo] assigns to [CCo] all of its right, title and interest in the Term Sheet and the Credit Facilities. * [ACo] represents that the Term Sheet is in full force and effect and unamended and [ACo] has not knowingly discharged [BCo] from the Term Sheet or assigned any rights or obligations under the Term Sheet; * [CCo] accepts the assignment of [ACo’s] rights and obligations in the Term Sheet and indemnifies [ACo] from any claims by [BCo] arising in connection with the Term Sheet or the performance of the Lender’s obligations under the Term Sheet; * [BCo] acknowledges that it has taken notice of the assignment and expressly consents to it. * The Assignment Agreement sets forth the entire agreement and understanding among the parties with respect to the subject matter and supersedes any prior agreements or understandings, whether oral or in writing. ...

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