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The policy is based on careful consideration of the Tax Court of Canada and Federal Court of Appeal decisions in Riverfront, the exemptions in the ETA that apply to supplies made by medical practitioners and practitioners, as well as the information provided by stakeholders on the issue. ...

The interpretation of section 2 and the revised interpretation of sections 5 and 7 of Part II of Schedule V, outlined below, are based on consideration of the decisions in Riverfront, the exemptions in the ETA that apply to supplies made by operators of health care facilities, medical practitioners and practitioners, as well as the information provided by stakeholders on the issue. ...

Further, section 165 of the ETA requires every recipient of a taxable supply (other than a zero-rated supply) made in Canada, to pay the GST or HST calculated on the value of the consideration for the supply. ...

Pursuant to subsection 165(1), "... every recipient of a taxable supply made in Canada shall pay to Her Majesty in Right of Canada tax in respect of the supply... on the value of the consideration for the supply... ...

Generally, a meeting or assembly is a "foreign convention" where: (a) the event is a "convention" as defined in subsection 123(1) of the ETA; (b) at least 75% of the admissions to which are, at the time the sponsor of the convention determines the amount to be charged as consideration therefore, reasonably expected to be supplied to non-resident persons; and (c) the sponsor of which is an organization whose head office is situated outside Canada or, where the organization has no head office, the member, or majority of members, of which having management and control of the organization is or are non-resident. ...

Anyone engaged in the activity of supplying dietetic services would have been making taxable supplies and would have been a GST/HST registrant prior to 1997 if the total value of the consideration for these supplies exceeded the $30,000 small supplier threshold. ...

Home medical supply The proposed legislation defines a "home medical supply" as an exempt supply (other than a facility supply or a prescribed supply) of property or a service (a) that is made (i) as part of a medically necessary process of health care for an individual for the purpose of maintaining health, preventing disease, diagnosing or treating an injury, illness or disability or providing palliative health care, and (ii) after a physician acting in the course of the practise of medicine, or a prescribed person acting in prescribed circumstances, has identified or confirmed that it is appropriate for the process to take place at the individual's place of residence or lodging (other than a public hospital or a qualifying facility), (b) in respect of which the property is made available, or the service is rendered, to the individual at the individual's place of residence or lodging (other than a public hospital or a qualifying facility), on the authorization of a person who is responsible for coordinating the process and under circumstances in which it is reasonable to expect that the person will carry out that responsibility in consultation with, or with ongoing reference to instructions for the process given by, a physician acting in the course of the practise of medicine, or a prescribed person acting in prescribed circumstances, (c) all or substantially all of which is of property or a service other than meals, accommodation, domestic services of an ordinary household nature, assistance with the activities of daily living and social, recreational and other related services to meet the psycho-social needs of the individual, and (d) in respect of which an amount, other than a nominal amount, is paid or payable as medical funding to the supplier; Medical Funding The term "medical funding" is defined as an amount of money (including a forgivable loan but not including any other loan or a refund, remission or rebate of, or credit in respect of, taxes, duties or fees imposed under any statute) that is paid or payable to the supplier in respect of health care services for the purpose of financially assisting the supplier in making the supply or as consideration for the supply by (a) a government, or (b) a person that is a charity, a public institution or a qualifying non-profit organization (i) one of the purposes of which is organizing or coordinating the delivery of health care services to the public, and (ii) in respect of which it is reasonable to expect that a government will be the primary source of funding for the activities of the person that are in respect of the delivery of health care services to the public during the fiscal year of the person in which the supply is made; XXXXX. ...

INTERPRETATION REQUESTED You would like to know whether, in consideration of the scenario provided: 1. ...

In particular, the issue that arises is the apparent lack of consideration payable by the Principals for the services of the Agent. ...

The General Application Division expects to have this policy before the Policy Review Committee for consideration by the end of November 1995. 2) XXXXX The second case submitted by XXXXX is in respect of the supply of emergency services to individuals involved in car accidents where such services are paid for by XXXXX wrote to the Department on May 5, 1994 regarding this issue. ...