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XXXXX cannot be considered to be "at risk" within the meaning of section 4 of the Financial Services (GST/HST) Regulations in respect of the sold mortgages. ...

Generally, to be considered “supplied by a charity under a contract for catering,” the sale of the beverages must be required pursuant to terms in the catering contract at the direction of the client and all or a portion of the consideration payable for the beverages must be billed to the catering client as part of the invoice for the catering supply. Therefore, a beverage sold by a charity at a private special event through either a host bar (that is, total amount for the beverages is charged to the catering client) or a partial payment host bar (for example, only 50% of the total amount for the beverages is charged to the catering client and the remaining 50% is charged to the guests) is generally considered to be supplied by a charity under a contract for catering and would be an exempt supply. ... For additional information on what is considered prescribed property and services for PSB rebate purposes, please refer to the section “Non-eligible purchases and expenses” in GST/HST Guide RC4034, GST/HST Public Service Bodies' Rebate, which is available on our website. ...

A BEE is considered to be situated on a reserve when the entity maintains a presence on a reserve. ... The following criteria are used to determine whether or not an entity meets the owned or controlled condition in the definition of a BEE: “An entity is considered to be owned by a band, tribal council or a group of bands other than a tribal council if: * the band, tribal council or group of bands owns all or substantially all [90 per cent or more] of the shares or holds all or substantially all of the memberships of the entity; or * the band, tribal council or group of bands holds title to the assets of the entity or controls its disposition, such that in the event of wind up or liquidation, these assets are vested in the band, tribal council or a group of bands. An entity is considered to be controlled by a band, tribal council or group of bands other than a tribal council if: * the band, tribal council, group of bands or individual members of the band, tribal council or group of bands, appoint or elect a majority of the members of the governing body of the entity (e.g., directors); and * the entity is required by legislation, by-laws, or an operating agreement, to submit to the band, tribal council or group of bands, its operating budget and where applicable, its capital budget for review and approval.” ...

Generally, to be considered “supplied by a charity under a contract for catering,” the sale of the beverages must be required pursuant to terms in the catering contract at the direction of the client and all or a portion of the consideration payable for the beverages must be billed to the catering client as part of the invoice for the catering supply. Therefore, a beverage sold by a charity at a private special event through either a host bar (that is, total amount for the beverages is charged to the catering client) or a 50/50 bar (that is, only 50% of the total amount for the beverages is charged to the catering client and the remaining 50% is charged to the guests) is generally considered to be supplied by a charity under a contract for catering and would be an exempt supply. ... For additional information on what is considered prescribed property and services for PSB rebate purposes, please refer to the section “Non-eligible purchases and expenses” in GST/HST Guide RC4034, GST/HST Public Service Bodies' Rebate, which is available on our website. ...

Generally, to be considered “supplied by a charity under a contract for catering,” the sale of the beverages must be required pursuant to terms in the catering contract at the direction of the client and all or a portion of the consideration payable for the beverages must be billed to the catering client as part of the invoice for the catering supply. Therefore, a beverage sold by a charity at a private special event through either a host bar (that is, total amount for the beverages is charged to the catering client) or a 50/50 bar (that is, only 50% of the total amount for the beverages is charged to the catering client and the remaining 50% is charged to the guests) is generally considered to be supplied by a charity under a contract for catering and would be an exempt supply. ... For additional information on what is considered prescribed property and services for PSB rebate purposes, please refer to the section “Non-eligible purchases and expenses” in GST/HST Guide RC4034, GST/HST Public Service Bodies' Rebate, which is available on our website. ...

. * Whether services performed by the Service Provider for the Company are considered to be a single supply or multiple supplies is a question of fact. ... If the predominant element of the single supply is determined to be a financial service, then the supply as a whole will be considered a financial service. * A service will be a financial service where it is included in any of paragraphs (a) to (m) of the definition of financial service in subsection 123(1) and is not otherwise excluded by any of paragraphs (n) to (t) of that same definition. * Based on the information provided to us, the ultimate Transaction could constitute a single exempt supply that is a financial service under one of paragraphs (a) through (i) of the definition of financial service in subsection 123(1); in particular, paragraph (d), which refers to the transfer of ownership of a financial instrument.- On this basis, it is necessary to consider whether the predominant element of the supply made by the Service Provider constitutes “arranging for” the Transaction, for purposes of paragraph 123(1)(l) of the definition of financial service.- However, in light of our advice regarding the “arranging for” issue, we are not providing conclusive advice with respect to the characterization, for GST purposes, of the Transaction. * Key services performed by the Service Provider under the Service Agreement (as set out above under the heading “Key Services Provided and Ultimate Transaction”) include advice on what form the transaction should take, as well as other advisory services, assistance in searching for a purchaser, and document preparation, all of which are taxable elements. ... Instead, the predominant element of the Service Provider's supply would be taxable advisory services. * Also, the Service Provider is not “arranging for” the Transaction based on CRA’s position, as set out in publications (for example, TIB B-105, Examples 16, 17) notwithstanding it may be considered a financial intermediary. ...

GST/HST Policy Statement P-229, entitled: Definition of "vocational school" in Section 1 of Part III of Schedule V to the Excise Tax Act, explains how to determine if an organization is a "vocational school" within the meaning of the ETA There are three principle criteria that an organization must meet to be considered a vocational school: (a) The organization must be established primarily to provide correspondence courses or instruction in courses, that develop or enhance students' occupational skills; (b) The organization must be operated primarily to provide correspondence courses or instruction in courses that develop or enhance students' occupational skills; (c) The correspondence courses or instruction in courses must develop or enhance students' occupational skills. ... With respect to the courses being offered, P-229 states: To be considered a vocational school the... instruction in courses offered by an organization must develop or enhance students' occupational skills. ... The instructor courses that train and test lifeguards would be considered to have a direct link to skills necessary for employment. ...

If [it] is determined that multiple supplies are being provided by a person the possible application of sections 138 and 139 should be considered. ... If the predominant element of the single supply is determined to be a financial service, then the supply as a whole will be considered a financial service. ... In determining if an intermediary's service is included in paragraph (l), all the facts surrounding the transaction, including the following factors, must be considered: • the degree of direct involvement and effort of the person in the provision of a financial service referred to in any of paragraphs (a) to (i); • the time expended by the intermediary in the provision of a financial service referred to in any of paragraphs (a) to (i); • the degree of reliance of either or both the supplier and the recipient on the intermediary in the course of providing a financial service referred to in any of paragraphs (a) to (i); • the intention of the intermediary to effect a supply of a financial service referred to in any of paragraphs (a) to (i); and • the normal activities of an intermediary in a given industry (including whether the intermediary is engaged in a business of providing financial services). ...

.], the [Organization] is also considered to make a supply to the [real property] owner (the improvement supply). ... Although the improvement inputs are acquired for the purpose of [...] these inputs may also be considered to be for use in making the improvement supply and a fair and reasonable ITC allocation method would reflect this. ... Please note that, for purposes of this response, we have not considered a situation where the [real property] owner is a commercial enterprise rather than a municipality. ...

You have requested our interpretation of the application of the Excise Tax Act (the "ETA") to the following: 1) That the Contracting Companies or the Contracting Professionals and MedCo will be considered to be medical practitioners for purposes of the ETA, as defined in Schedule V, Part II, section 1. 2) That the consideration received by the Contracting Companies or the Contracting Professionals from MedCo to practise medicine as independent contractors is received for consultative, diagnostic, treatment or other health care services rendered to an individual. 3) That the consideration received by MedCo from an individual or a third party (for medical services) is received for a service rendered to an individual. ... Interpretations Given You have asked whether the Contracting Companies, the Contracting Professionals and MedCo will be considered to be medical practitioners for purposes of the ETA, as defined in Schedule V, Part II, section 1. ... Among the factors that must be considered are the specific provisions of any contracts or agreements between the parties describing what supplies are to be made. ...