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31 October 2000 GST/HST Interpretation 31659 - Supply of Services Performed in Canada for Non-resident Health Care/Medical Providers in Connection With the Retention of Their Records and Files

31 October 2000 GST/HST Interpretation 31659- Supply of Services Performed in Canada for Non-resident Health Care/Medical Providers in Connection With the Retention of Their Records and Files Unedited CRA Tags ETA 142(1)(g); ETA Sch VI, Part V, 4 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXX Case: 31659October 31, 2000 Subject: GST/HST INTERPRETATION XXXXX Thank you for your letter of May 29, 2000 concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST), and more particularly section 4 of Part V of Schedule VI to the Excise Tax Act (the Act), to the supply of services performed in Canada by Storageco for non-resident health care/medical providers in connection with the retention of their records and files. ...

Progressive/Waste Management -- summary under Inversions

The shares of Progressive will then be consolidated (so that the Waste Connections shareholders have the same number of shares as before) – and Progressive will be renamed Waste Connections by means of amalgamation with a shell Ontario subsidiary with that name. ... Merger Merger Sub will merge with and into Waste Connections (the ''Merger''), with Waste Connections continuing as the surviving corporation and a subsidiary of Progressive. On the Merger, Waste Connections stockholders will receive newly issued Progressive common shares as consideration under the Merger at an exchange ratio of 2.076843 Progressive common shares for every one common share of Waste Connections common stock, so that Progressive and Waste Connections stockholders will hold approximately 30% and 70%, respectively, of post-Merger Progressive common shares. ...

Progressive/Waste Management -- summary under Reverse takeovers

Progressive/Waste Management-- summary under Reverse takeovers Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Reverse takeovers reverse takeover of Progressive Waste Solutions by Waste Management under Delaware merger Overview It is proposed that Waste Connections, a NYSE-listed Delaware corporation, will effect a reverse takeover of Progressive, a TSX and NYSE-listed OBCA corporation, through a merger of Waste Connections with a Delaware shell sub of Progressive, with Waste Connections as the survivor and with Waste Connections’ shareholders receiving common shares of Progressive so as to end up holding 70% of Progressive. The shares of Progressive will then be consolidated (so that the Waste Connections shareholders have the same number of shares as before) – and Progressive will be renamed Waste Connections by means of amalgamation with a shell Ontario subsidiary with that name. ... Treasury Department and IRS proposals, that could cause intercompany debt if it were to exceed the currently outstanding debt of Waste Connections to be treated as equity, would reduce the adjusted free cash flow expected in the first year following the Merger by less than 3%. ...

S1-F3-C4 - Moving Expenses -- summary under

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ...

S1-F3-C4 - Moving Expenses -- summary under Eligible Relocation

Required connection between move and employment/business/education 4.7 To satisfy the condition described in ¶ 4.3(a) or ¶ 4.4 (a), there must be a connection between the individual’s move and one of the following activities: carrying on a business or being employed at a location in Canada or attending an educational institution. Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ...

InnVest REIT -- summary under Fund Debenture Offer

" Part XIII tax "By virtue of the fact that the Series G Debentures are convertible into Units of the REIT, there is a risk that both (i) the amount of the Offer Price that exceeds the principal amount of the Series G Debentures (the "Excess"); and (ii) all interest paid or deemed to be paid to a Non-Resident Holder in connection with the Offer could be considered to be participating debt interest, in which case Canadian withholding tax would apply. ... As a result there is a risk that both (i) the Excess; and (ii) all interest paid or deemed to be paid to a Non-Resident Holder in connection with the Offer could be subject to Canadian withholding tax. ...

Shred-it TRA -- summary under Loss Utilizations/TRAs

In connection with the Offering. Shred-it will acquire all of the common shares of the General Partner. ... In connection with the Offering, Shred-it also will have contributed its general partner interest in Boost Holdings LP to a wholly-owned subsidiary ("New GP"). ... Our payment obligations under the TRA with respect to interests in the Partnership treated as sold for U.S. federal income tax purposes to us in connection with this Offering are expected to be calculated based on the Offering Price, net of Underwriters' Commission and other Offering related costs. ...

Agellan -- summary under Cross-Border REITs

The anti-inversion rules in Code s. 7874 are not expected to apply as the REIT will have substantial business activities in Canada and because the number of Units issued in connection with the US property acquisitions is not expected to exceed 60% of the total Units issued in connection with all the property acquisitions. ...

Cominar/Canmarc -- summary under Trust Acquisitions of Trusts

Non-residents A Non-Resident Holder whose Canmarc Units (or units of Canmarc which have been received in exchange for Canmarc Units) are redeemed by Canmarc pursuant to the Subsequent Acquisition Transaction will be subject to Canadian withholding tax at the rate of 25%, unless such rate is reduced under the provisions of an applicable tax treaty, on that portion of Canmarc's income (other than taxable capital gains designated by Canmarc in respect of the Non-Resident Holder) for the taxation year as is allocated and paid by Canmarc to the Non-Resident Holder in connection with the redemption of such units. There would be Canadian withholding tax at the rate of 25% on an amount which is allocated and paid by Canmarc to the Non-Resident Holder in connection with the redemption of the Non-Resident Holder's units if Canmarc has a "TCP Gains Balance" (as defined in the Tax Act) at that time, but only if Canmarc designates more than 5% of the related net taxable capital gains for the year to Canmarc unitholders that are either Non-resident persons or partnerships which are not "Canadian partnerships. ...

Power/Lumenpulse -- summary under Privatizations

The proceeds will be used to finance a portion of the total consideration payable by the Purchaser in connection with the Arrangement. Equity financing of privatization On April 26, 2017, the Purchaser entered into equity commitment letters with each of Power Energy and Mica3 (an entity controlled by Michel Ringuet, a director of the Corporation) pursuant to which they agreed to make direct or indirect cash equity investments in the Purchaser in a maximum aggregate amount of $277,000,000 in the case of Power Energy (such amount to be reduced, as applicable, in the event that the Purchaser does not require the full amount by reason of the Purchaser having obtained funds from other sources) and $3,000,000 in the case of Mica3 to finance a portion of the total consideration payable by the Purchaser in connection with the Arrangement. ...

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