CRA construes voluntary GST registration provision broadly

The ETA stipulates that a non-resident who is not engaged in commercial activity in Canada but which "regularly solicits orders" for the supply by it of tangible personal property to Canadians may voluntarily register for GST purposes. However, the CRA will register a non-resident person that purchases and sells taxable tangible personal property for delivery in Canada in the ordinary course of carrying on a business outside Canada, but does not regularly solicit orders in respect of such sales.

Neal Armstrong.  Summary of CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 14. ("Voluntary Registration") (available with membership password at http://www.cba.org/CBA/sections_NSCTS/main/GST_HST.aspx), under ETA, s. 240(3)(b).