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The RITC requirement will generally not apply to specified energy acquired by a sponsor or organizer of a convention for use exclusively at that convention. ... Example 22 An organizer of a domestic convention pays for electricity that will be for use exclusively at the convention held in Toronto. ... However, the RITC requirement will generally not apply to: internet access services; web-hosting services; toll-free telephone services (e.g., 1-800, 1-866, 1-888 or 1-877 telephone services) or a telecommunication service related to toll free telephone services; and telecommunication services acquired by a sponsor or organizer of a convention for use exclusively at that convention. ...

However, the term permanent establishment is also defined in detail in each reciprocal income tax treaty or convention that Canada has with another country. When determining whether a permanent establishment exists, the definition under a treaty or convention always takes precedence over the definition in the Regulations. Determining whether a permanent establishment exists in Canada, according to the definition in the Regulations or a tax treaty or convention, relies on the definition of a fixed place of business. ...

The definitions accredited representative ss 2(1) Effective February 13, 1992, means a person who is entitled to the tax exemptions specified in Article 34 of the Convention set out in Schedule I to the Foreign Missions and International Organizations Act or Article 49 of the Convention set out in Schedule II to that Act; adjustment Part VII, ss 70.1(1) In this section, "adjustment" to the sale price of goods means the giving of a discount, allowance, rebate or other amount as a reduction in the sale price; alcohol Part III, ss 23.4(1) In this section, effective April 1, 1992, means ethanol and methanol produced from biomass or renewable feedstocks, but does not include ethanol or methanol produced from petroleum, natural gas or coal; amount owing Part VII, ss 81.13(7) For the purposes of this section and section 81.14, "amount owing", in respect of a person assessed, means, (a) where the assessment is an original assessment, the amount by which (i) the aggregate of all taxes, penalties, interest and other sums remaining unpaid by that person, as set out in the notice of assessment pursuant to subsection (2), exceeds (ii) the aggregate of (A) all amounts payable to that person, as set out in the notice of assessment pursuant to subsection (3), and (B) the credits allowable to that person, as set out in the notice of assessment pursuant to subsection (4), and (b) where the assessment is a variation of an assessment, or a reassessment, the amount by which (i) the amount obtained by subtracting (A) the amount paid by that person on account of the amount owing as set out in the notice of the original assessment or any subsequent assessment related thereto (B) the aggregate of all taxes, penalties, interest and other sums remaining unpaid by that person, as set out in the notice of the varied assessment or reassessment pursuant to subsection (2), exceeds (ii) the amount obtained by subtracting (A) the amount paid to that person pursuant to subsection 81.14(1) in respect of an overpayment as set out in the notice of the original assessment or any subsequent assessment related thereto from (B) the aggregate of (I) all amounts payable to that person, as set out in the notice of the varied assessment or reassessment pursuant to subsection (3), and (II) the credits allowable to that person, as set out in the notice of the varied assessment or reassessment pursuant to subsection (4); amount owing Part VII, ss 81.15(11) for the purposes of this section and section 81.16, "amount owing", in respect of a person objecting, means the amount by which (a) the amount obtained by subtracting (i) the amount paid by that person on account of the amount owing as set out in the notice of assessment from (i) the aggregate of all taxes, penalties, interest and other sums remaining unpaid by that person, as set out in the notice of decision pursuant to subsection (6) exceeds (b) the amount obtained by subtracting (i) the amount paid to that person pursuant to subsection 81.14(1) from (ii) the aggregate of (A) all amounts payable to that person, as set out in the notice of decision pursuant to subsection (7), and (B) the credits allowable to that person, as set out in the notice of decision pursuant to subsection (8); amount payable Part VII, ss 81.17(6) for the purposes of this section and section 81.18, "amount payable", in respect of a person objecting, means the amount by which (a) the aggregate of all amounts payable to that person pursuant to sections 68 to 69 (b) the amount paid to that person pursuant to subsection 72(6) or authorized to be deducted by that person pursuant to subsection 74(1); application Part VII, ss 72(1) in this section, means an application under any of sections 68 to 69; arm's length sale Part VII, ss 68.15(1) in this section, means the provision of a taxable service for an amount charged by a licensee to a person with whom the licensee is dealing at arm's length at the time the service is provided; arm's length sale Part VII, ss 68.21(1) in this section, means a sale of goods by a licensed manufacturer to a person with whom the manufacturer is dealing at arm's length at the time of the sale; assessment Part VII, ss 58.1(1) in Part VII, means an assessment under subsection 81.1(1) and includes a variation of an assessment and a reassessment; Atlantic manufactured tobacco ss 2(1) effective February 11, 1994, means manufactured tobacco (a) in respect of which the excise taxes imposed under section 23 have been paid or are payable at (i) the rates applicable before February 9, 1994, (ii) the rates applicable after February 8, 1994 under paragraphs 1(f), 2(d) and 3(e) of Schedule II, or (iii) the rate applicable after May 31, 1994 and before September 12, 1994 under paragraph 1(e) of Schedule II, and (b) that is marked or stamped "ATLANTIC" or "ATLANTIQUE" to indicate that it is intended for retail sale in the Provinces of Nova Scotia, New Brunswick, Prince Edward Island and Newfoundland but not marked or stamped to indicate that it is intended for retail sale specifically in the Province of Nova Scotia or New Brunswick; aviation fuel Part VII, ss 68.4(1) in this section, effective June 23, 1992, does not include aviation gasoline; band Part III, ss 23.36(1), Part VII, ss 68.165(1) and 97.5(1) in these sections, has the same meaning as in subsection 2(1) of the Indian Act; Note: effective dates are as follows: subsections 23.36(1) and 68.165(1)- April 15, 1994; and subsection 97.5(1)- June 23, 1994. black stock ss 2(1) effective February 11, 1994, means manufactured tobacco that is (a) stamped in accordance with the Excise Act and the departmental regulations made under that Act to indicate that the duties of excise and excise tax imposed on the manufactured tobacco have been paid, and (b) not stamped or marked in accordance with any statute of a province to indicate that the manufactured tobacco is intended for retail sale in a particular province or in particular provinces; black stock cigarettes ss 2(1) effective February 11, 1994, means cigarettes that are black stock; black stock manufactured tobacco ss 2(1) effective February 11, 1994, means black stock other than cigarettes and tobacco sticks; carrier Part VII, ss 68.4(1) in this section, effective June 23, 1992, "carrier" in a calendar year means a person whose gross revenue for the year is derived primarily from the business of providing eligible transportation services and who is not exempt for any period in the year from taxation under Part I of the Income Tax Act by reason of section 149 of that Act; cigar ss 2(1) effective February 13, 1992, has the meaning assigned by section 6 of the Excise Act; cigarette ss 2(1) effective February 13, 1992, has the meaning assigned by section 6 of the Excise Act; council Part III, ss 23.36(1), Part VII, ss 68.165(1) and 97.5(1) in these sections, "council" of a band has the same meaning as in subsection 2(1) of the Indian Act; Note: effective dates are as follows: subsections 23.36(1) and 68.165(1)- April 15, 1994; and subsection 97.5(1)- June 23, 1994. ...

GST/HST forms GST20 – Election for GST/HST Reporting Period GST70 – Election or Revocation of an Election to Change a GST/HST Fiscal Year GST71 – Notification of Accounting Periods GST74 – Election and Revocation of an Election to Use the Quick Method of Accounting GST115 – GST/HST Rebate Application for Tour Packages GST190 – GST/HST New Housing Rebate Application for Houses Purchased from a Builder GST322 – Certificate of Government Funding GST386 – Rebate Application for Conventions RC366 – Direct Deposit Request – GST/HST, Payroll and/or Corporation Income Tax RC4601 – GST/HST Reporting Entity Election for a Selected Listed Financial Institution and Notice of Revocation RC4602 – Request for a Group GST/HST Registration Number for Selected Listed Financial Institutions with Consolidated Filing RC4602-1 – Request to be Added to a Group GST/HST Registration for Selected Listed Financial Institutions with Consolidated Filing RC4603 – GST/HST Tax Adjustment Transfer Election for a Selected Listed Financial Institution and Notice of Revocation RC4604 – GST/HST Consolidated Filing Election for a Selected Listed Financial Institution and Notice of Revocation RC4604-1 – Election for a Selected Listed Financial Institution to Join a GST/HST Consolidated Filing Election RC4604-2 – Election for a Selected Listed Financial Institution to Withdraw From a GST/HST Consolidated Filing Election RC4605 – Total Tax Recovery Rate Election and Revocation for a Selected Listed Financial Institution RC4606 – Election or Revocation for a Qualifying Small Investment Plan to be Treated as a Selected Listed Financial Institution RC4607 – GST/HST Pension Entity Rebate Application and Election RC4609 – Election or Revocation of Election to Use the Real-Time Calculation Method or the Reconciliation Method RC4610 – Election to have Subsection 225.4(3), (4) or (5) Not Apply to Non-Resident Investments in Certain Selected Listed Financial Institutions and Notice of Revocation GST/HST guides RC4034 – GST/HST Public Service Bodies' Rebate RC4082 – GST/HST Information for Charities RC4160 – Rebate for Tour Packages, Foreign Conventions, and Non-Resident Exhibitor Purchases GST/HST info sheets GI-127 – Documentary Evidence when Making Tax-Relieved Sales to Indians and Indian Bands over the Telephone, Internet and Other Electronic Means GI-128 – Harmonized Sales Tax: Proposed Enhancements to the British Columbia New Housing Rebates GI-129 – Harmonized Sales Tax: Proposed Enhancements to the British Columbia New Residential Rental Property Rebates GI-130 – Stated Price Net of the Enhanced British Columbia New Housing Rebate GST/HST memoranda 8-4 – Documentary Requirements for Claiming Input Tax Credits 14-5 – Election for Nil Consideration GST/HST notices NOTICE264 – Sales Made to Indians and Documentary Evidence – Temporary Confirmation of Registration Document NOTICE276 – Elimination of the HST in British Columbia in 2013 – Transitional Rules for Real Property Including New Housing NOTICE277 – The Nekaneet First Nation Implements the First Nations Goods and Services Tax Excise duty forms E146 – Amended Plans and Specifications Excise duty memoranda EDM1-1-1 – The Excise Duty Program (revised) EDM10-1-9 – Completing an Excise Duty Return – Tobacco Dealer (revised) EDM10-3-1 – Refunds (revised) Softwood lumber products export charge notices SWLN43 – Surge Charge – Alberta Region (July 2012) 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. ...

Tax Convention is by far our most complex; changes made to the Convention were effective in January 2009. ...

In Canada, it involves transactions, arrangements or events that are normally fully disclosed but undertaken to achieve a tax result that is not supportable within specific anti-avoidance provisions or the overall scheme of the Income Tax Act, Excise Tax Act, or Income Tax Conventions. ...

ITSC and SIAD maintain separate lists of TRAs for national applications, but the lists are inconsistent due to differing naming conventions and historical tracking efforts. ...

Tax Convention. The treaty contains robust safeguards to ensure the Internal Revenue Service will treat taxpayer information confidentially, and use the information solely to administer tax laws. ...

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. ...

Information is typically exchanged to either ascertain the facts in relation to which rules of an income tax convention are to be applied or to assist one of the contracting parties in administering and enforcing its domestic tax law. ...