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Exposé des faits Vous avez fourni les renseignements suivants pour notre considération: Le 21 décembre 1989, XXXXX et un acquéreur, tous deux inscrits depuis XXXXX ont conclu un contrat par écrit en vue de l'opération de terrains de stationnement XXXXX. ...

In addition "improvement", for purposes of Part IX of the ETA and the Regulations thereto is defined in subsection 123(1) as: "in respect of property of a person, means any property or service supplied to, or goods imported by, the person for the purpose of improving the property, to the extent that the consideration paid or payable by the person for the property or service or the value of the goods is, or would be if the person were a taxpayer under the Income Tax Act, included in determining the cost or, in the case of property that is capital property of the person, the adjusted cost base to the person of the property for the purposes of that Act;" Therefore, based upon the above Statement of Facts the municipality as a registrant would not be eligible to claim ITCs for GST that was paid or became payable in respect of the acquisition of improvements to real property (i.e. improvements to land) where the real property was acquired by the municipality by way of lease. ...

In addition "improvement", for purposes of Part IX of the ETA and the Regulations thereto is defined in subsection 123(1) as: "in respect of property of a person, means any property or service supplied to, or goods imported by, the person for the purpose of improving the property, to the extent that the consideration paid or payable by the person for the property or service or the value of the goods is, or would be if the person were a taxpayer under the Income Tax Act, included in determining the cost or, in the case of property that is capital property of the person, the adjusted cost base to the person of the property for the purposes of that Act;" Therefore, based upon the above Statement of Facts the municipality as a registrant would not be eligible to claim ITCs for GST that was paid or became payable in respect of the acquisition of improvements to real property (i.e. improvements to land) where the real property was acquired by the municipality by way of lease. ...

Each case must be determined based on the facts of that case, taking into consideration the history of the persons activities as well as the person's intention. ...

This would include property that XXXXX acquires with the intent and for the purpose of being exclusively supplied in the same form ("as is") for monetary consideration from category 1 suppliers, as well as property that XXXXX acquires in bulk format from category 2 suppliers, which XXXXX breaks down into smaller quantities, repackages and/or cleans, and then in turn supplies exclusively by way of sale for a price in money. 2. ...

., a person who is liable to pay the consideration for a supply) who so acquire these motor vehicles for use in their commercial activities, those members are entitled to claim an input tax credit, unless of course the original supply of the motor vehicles are zero-rated (e.g., taxed at zero per-cent). ...

Consequently, tax at the GST rate of 7% on the value of the consideration for the taxable supply applies pursuant to subsection 165(1) of the ETA unless the supply is a zero-rated supply pursuant to Part V of Schedule VI to the ETA and taxed at the rate of 0% pursuant to subsection 165(3) of the ETA. ...

Therefore, in consideration of the above information, the supply of the motor vehicle made by Canco to USco may be zero-rated by virtue of Section 1 of Part V of Schedule VI to the Act if all of the conditions set out above have been met. ...

Other than for the purposes of section 193 and 257, that sale is deemed to be made for no consideration. ...

., the person who is liable to pay the consideration for the supply) of the initial supply from the third party. ...