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. … A person shares mining payments when the person shares in the risk of success in the mining activities of the group. … Where a person receives a direct share of the actual mining payment, or a payment or adjustment that is determined based on the actual mining payment earned by the pool or the operator, the person is generally considered to share in the mining payments. ... Another factor to consider in determining whether persons share mining payments within a mining group is whether the operator charges fees to persons with respect to the management or administration of the mining endeavours. … [T]he following types of arrangements for mining would be indicative of a person and a mining pool operator not being members of the same mining group for the purposes of section 188.2: The person is paid by the mining pool operator for the contribution of computing resources by the person and the payment is based on the expected value of the number of blocks validated calculated based on the expected block subsidy regardless of whether the activity gives rise to an actual block subsidy or transaction fee [and similarly where such expected value also includes expected transaction fees]. … Such [person’s] supply is subject to the general GST/HST rules ….. ...