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Meaning of in Respect of Real Property Situated in Canada and in Respect of Tangible Personal Property that is Situated in Canada at Time the Service is Performed, for Purposes of Schedule VI, Part V, Sections 7 and 23 to the Excise Tax Act

Therefore, a connection existed between the service and the property. ... Therefore, there was a connection between the service and the property. ... There is a direct connection between the services and the property. 5. ...

5 July 2012 GST/HST Ruling 137345 - Eligibility to claim input tax credits on pension related expenses

., audit and actuarial) incurred in connection with the administration of the Plan. ... However, the Company must also account for GST/HST on amounts reimbursed by the Funding Agent in connection with these expenses. ... A commercial activity also includes 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. ...

31 August 2004 GST/HST Interpretation 50657 - Deferred Finance Mortgage Revenue

If some object comes between the service and the TPP, the connection becomes increasingly remote. ... To the extent that such claims arise as a result of the existence of a particular product, there can be a connection between the legal service and the product. ... Therefore, the connection between the legal service and the product giving rise to the product liability claim would generally be indirect and would not be excluded from zero-rating under paragraph 23(c) of Part V of Schedule VI of the ETA on the basis of being a service in respect of TPP that is in Canada at the time the service is performed. ...

16 February 1994 GST/HST Interpretation 11585-13[2] - Limited Partnerships and Entitlement to Input Tax Credits

It is our view that even in the absence of such provisions, activities done in connection with the acquisition, establishment, disposition or termination (and reorganization in the case of paragraph 141(5)(c)) of a commercial activity are still part of the commercial activity. ... They import such meanings as "in relation to", "with reference to", or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...

23 November 2000 GST/HST Interpretation 31630 - Transportation of Pets by Air

This usually means that the item is given a baggage slip indicating the flight number, connections and destination airport that the passenger follows. ... The transportation of the pet in the scenario described would be treated as the transportation of the passenger's baggage to the extent that the pet is being transported and tracked in direct connection with the passenger's flight and not distinctly shipped as cargo with a corresponding waybill. ... The excess baggage charge made on a return leg of the round trip in question is considered to be in connection with the passenger transportation service. ...

Bessette v. Quebec (Attorney General), 2019 FC 393

This presentation was made in 2015 by officials of the MSSS and RAMQ, in connection with the related file brought before the Superior Court of Quebec. ... This does not help me in view of the conclusions I have already drawn in connection with Mr. ... April relies on his comments made in connection with claims 9 and 10 for claims 33 and 34, claims 3 and 4 for claims 35 and 36, and claims 13 and 14 for claims 39 and 40 (April Report, March 9, 2018, at paras 298-301). ...

2010 Ruling 2010-0357061R3 - Split-up butterfly

None of the issues involved in this ruling request are: (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (v) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... In connection with the winding-up of DC, DC will distribute all of its assets and liabilities, and in particular, DC will assign and distribute the TC1 Note to TC1, the TC2 Note to TC2 and the TC3 Note to TC3 and TC1 will assume the DC1 Note, TC2 will assume the DC2 Note and TC3 will assume the DC3 Note. 47. ... In connection with the distribution of property described in Paragraph 39, TC1, TC2 and TC3 will enter into a co-ownership agreement with respect to their interests in the XXXXXXXXXX Property, the XXXXXXXXXX Property, the XXXXXXXXXX Property and the XXXXXXXXXX Property. ...

25 February 2014 Internal T.I. 2013-0475161I7 - Whether USCo has a PE in Canada

(footnote 2) USCo has signed a Master Services Agreement with XXXXXXXXXX under which USCo provides services to XXXXXXXXXX and its affiliates in connection with the XXXXXXXXXX operations. ... Any services performed at a construction site (assuming that they have some connection to that site) is governed by the construction site provision. ... However, planning and supervision is not included if carried out by another enterprise whose activities in connection with the construction concerned are restricted to planning and supervising the work. ...

2013 Ruling 2013-0475681R3 - Family holding butterfly transaction

We understand that, to the best of your knowledge and that of the taxpayers, none of the issues involved in the ruling request is: (a) in an earlier return of the taxpayers or a related person, (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person, (c) under objection by the taxpayers or a related person, (d) before the courts, or (e) the subject of a ruling previously considered by the Directorate involving the taxpayers or a related person. ... In connection with the winding-up of DC, DC will assign and distribute the TC1 Note 1, 2 and 3 to TC1, the TC2 Note 1, 2 and 3 to TC2, the TC3 Note 1, 2 and 3 to TC3, the TC4 Note 1, 2 and 3 to TC4 and the TC5 Note 1, 2 and 3 to TC5. 54. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

2014 Ruling 2013-0513211R3 - Butterfly Transaction

You have advised that to the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein are: a) in an earlier tax return of the taxpayer or a related person; b) being considered by a Tax Services Office or Taxation Centre in connection with any tax return previously filed by the taxpayer or a related person; c) under objection or appeal by the taxpayer or a related person; d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ... In connection with the winding-up of DC Amalco, DC Amalco will assign and distribute the Subco1 Redemption Note to TC1, the Subco2 Redemption Note to TC2 and the Subco3 Redemption Note to TC3. ... An invoice for our fees in connection with this ruling request will be forwarded to you under separate cover. ...

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