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GST/HST Interpretation

3 September 2004 GST/HST Interpretation 48298 - Place of Supply of Services

As set out in GST/HST policy statement P-169R (P-169R Meaning of "in respect of real property situated in Canada" and "in respect of tangible personal property that is situated in Canada at the time the service is performed", for purposes of Schedule VI, Part V, sections 7 and 23 to the Excise Tax Act), and GST/HST Memorandum Series, Section 4.5.3, Exports- Services and Intellectual Property, the CRA's position is that there must be more than a mere indirect or incidental connection between a service and the underlying tangible personal property before the supply of the service will be considered to be "in respect of" the property and consequently excluded from zero-rating. ...
GST/HST Interpretation

3 September 2004 GST/HST Interpretation 50304 - Supply of Services to a Non-Resident

The following are considered to be essential qualities of an agency relationship: 1. ...
GST/HST Interpretation

12 July 2004 GST/HST Interpretation 49606 - PROPOSED LAW/REGULATION Eligibility to claim input tax credits related to pension plan expenses

The person is considered to have paid as recipient and collected as supplier tax calculated on the FMV of the complex at the later of the times set out in paragraph 191(3)(d). ...
GST/HST Interpretation

29 June 2004 GST/HST Interpretation 52146 - Request for Designation as a "hospital authority" by the XXXXX

However, as such an expense is not determinative of whether a reasonable expectation of profit existed with respect to the Land leases, it cannot be considered for that purpose. ...
GST/HST Interpretation

3 June 2004 GST/HST Interpretation 33953 - Request for designation as a "hospital authority" and as a "municipality" by XXXXX

These payments are considered to have been made in the public interest for the direct benefit of the City and its residents. ...
GST/HST Interpretation

16 April 2004 GST/HST Interpretation 48059 - Leasehold Interest in Ground Lease

Notwithstanding that the exterior cladding and the applicable costs are discussed, there is no mention of a XXXXX year rent-free holiday in the letter- rather a proposal to adjust the ground rent (For purposes of this ruling this reference to "ground rent" is viewed as equivalent to Base Rent.) payment is considered. ...
GST/HST Ruling

14 July 2005 GST/HST Ruling 45299 - S AND INTERPRETATIONS XXXXX

When transactions of other residential complexes or units are considered for purposes of determining the FMV of the MURC, such residential complexes or units would need to be sufficiently comparable to the MURC. ...
GST/HST Interpretation

18 August 2005 GST/HST Interpretation 58786 - Direct Sellers - Sales Aids

There are certain requirements to be considered when cancelling your registration. ...
GST/HST Interpretation

7 February 2006 GST/HST Interpretation 59954 - AND APPLICATION RULING [Application of the GST/HST to the Supply of Various Camp Programs to Children and Youth]

In respect of services, such as a camping program, this provision would only be considered in instances where a service is acquired by the charity for re-supply in the same form as it was acquired. ...

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