Search - connection

In this connection, we would mention that there are no exemptions in the ETA for XXXXX. ...

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. ...

XXXXX the Agreement states, in part, that each carrier shall pay their respective licences and registration fees, taxes, added value taxes, assessments or charges, levied or rated or charged all in connection with each carrier performing the interline services contemplated under this Agreement. 4. ...

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[.] ...

The phrase "through which the particular person makes supplies" in paragraph 123(1)(a) suggests that a supply must have some connection with the "fixed place of business". ...

In addition, pursuant to paragraph 141.1(3)(b) a person that does anything (other than making a supply) in connection with the acquisition, establishment, disposition or termination of an activity of the person that is not commercial activity, that person is deemed to have done that thing otherwise than in the course of commercial activities. ...

I understand that none of the issues herein is being considered by a Revenue Canada Tax Services Office in connection with a GST return already filed and none of the issues is under objection or appeal. ...