I have reviewed the 2 letters and I am of the opinion that the February, 2002 ruling from CCRA's GST Ruling office is the correct interpretation of the issue as opposed to the opinion of Canada's former Finance Minister.

Unless the relevant provisions of the Excise Tax Act identified in the ruling under the heading "Explanation" have been amended since 2002 to include CAT's as practitioners or alternatively, athletic therapy services are now covered under Manitoba's Health Insurance Plan, the ruling would still apply today and accordingly, CAT's would be required to charge and collect GST on services rendered.

Peter G. Andrekson
Miles Davison McCarthy McNiven LLP

CATA Lawyer