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Should any taxation authority reassess a transaction covered by the Small Business APA, taxpayers will maintain any right to seek relief from double taxation pursuant to the pertinent provisions of the relevant bilateral Income Tax Convention. ...

. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

However, lower rates of tax may apply in accordance with the terms of an income tax agreement or convention with the country where the customer resides. ...

GST/HST forms E410 Waiver GST159 Notice of Objection (GST/HST) RC59 Business Consent Form RC325 Address change request RC4530 Election or Revocation of an Election to use a Production Proxy to Report the Recapture of Input Tax Credits RC4607 GST/HST Pension Entity Rebate Application and Election GST/HST guides RC4036 GST/HST Information for the Travel and Convention Industry (revised) GST/HST notices NOTICE259 Information Requirements Related to Investments in Selected Listed Financial Institution Distributed Investment Plans (other than Exchange-Traded Funds or Exchange-Traded Series) NOTICE260 Modified Procedures for Filing Form RC4604, GST/HST Reporting Entity, Consolidated Filing and Tax Adjustment Transfer Elections and Revocations for a Selected Listed Financial Institution NOTICE261 Information Required for Tax Adjustment Notes Issued by an Employer to a Pension Entity and the Consequential Notices Issued by the Pension Entity NOTICE262 Notice of Change, GST/HST Memorandum 28-3, Passenger Transportation Services NOTICE263 Maa-nulth First Nations NOTICE264 Sales Made to Indians and Documentary Evidence- Temporary Confirmation of Registration Document NOTICE265 GST/HST Registration for Listed Financial Institutions (Including Selected Listed Financial Institutions) NOTICE266 For discussion purposes only – Draft GST/HST Technical Information Bulletin, Harmonized Sales Tax – Self-assessment of the provincial part of the HST in respect of property and services brought into a participating province NOTICE267 Buffalo Point First Nation Implements the First Nations Goods and Services Tax GST/HST info sheets GI-121 Determining Whether a Public Service Body is Resident in a Province for Purposes of the Public Service Bodies' Rebate GI-122 The GST/HST Implications of the Acquisition of Solar Panels Under the micro Feed-in Tariff Program in Ontario GI-123 Application of GST/HST to Residential Care Services Provided in Ontario GST/HST technical information bulletins B-032 Registered Pension Plans (revised) B-097 Determining Whether a Financial Institution is a Qualifying Institution for Purposes of Section 141.02 (revised) B-098 Application of Section 141.02 to Financial Institutions That Are Qualifying Institutions (revised) B-099 Application of Section 141.02 to Financial Institutions That Are Not Qualifying Institutions (revised) B-106 Input Tax Credit Allocation Methods for Financial Institutions for Purposes of Section 141.02 of the Excise Tax Act B-107 Investment Plans (Including Segregated Funds of an Insurer) and the HST Softwood lumber products export charge notices SWLN41 Surge Charge – Alberta Region (September 2011) All GST/HST, Excise Duty, and Excise Taxes and Special Levies publications can be found on the CRA Web site at www.cra.gc.ca/gsthsttech, at www.cra.gc.ca/etsl, and at www.cra.gc.ca/exciseduty. ...

Decision The following facilities are all establishments that commonly come within the application of paragraph 1(q): restaurants and drive-in restaurants fast food outlets or "quick service" outlets takeout and home delivery outlets pubs, taverns, bars and lounges cafeterias and dining rooms lunch counters, coffee shops and snack bars mobile canteens catering services hotels, motels and lodging houses private or social clubs, and similar places or establishments where prepared food products are provided convention centres sports arenas and stadiums meeting halls and union halls passenger transportation vehicles of any type wherein food and/or beverages are provided for a separate consideration any eating facility within a business entity, for example, a lunch counter within a retail department store Under the last example, where an eating facility within a larger entity makes substantially all taxable sales, this eating facility is considered to be a separate entity, and is considered to be an establishment for purposes of paragraph 1(q) of Part III of Schedule VI to the Act. ...

For more information, refer to Foreign Conventions and Tour Incentive Program- Non-Residents Purchasing Tour Packages: Rebate for Eligible Tour Packages (GI-032). ...

. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

For more information on a continuous journey, go to GST/HST Information for the Travel and Convention Industry. ...

For more information, refer to GST/HST Info Sheet GI-032, Foreign Conventions and Tour Incentive Program – Non-Residents Purchasing Tour Packages: Rebate for Eligible Tour Packages. ...

For more information, refer to Foreign Conventions and Tour Incentive Program- Non-Residents Purchasing Tour Packages: Rebate for Eligible Tour Packages (GI-032). ...