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GST/HST Interpretation

22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]

(Footnote 1) [INTERPRETATION REQUESTED] [Are the Canada Emergency Wage Subsidy (“CEWS”) and the 10% Temporary Wage subsidy for Employers (“TWS”) considered government funding for purposes of the Public Service Bodies’ (“PSB”) Rebate] [INTERPRETATION GIVEN] […] For purposes of the PSB rebate, “government funding” is defined in section 2 of the Public Service Body Rebate (GST/HST) Regulations as (a) an amount of money (including a forgivable loan but not including any other loan or a refund, rebate or remission of, or credit in respect of, taxes, duties or fees imposed under any statute) that is readily ascertainable and is paid or payable to the particular person by a grantor i. for the purpose of financially assisting the particular person in carrying out the purposes of the particular person and not as consideration for supplies made by the particular person, or ii. as consideration for making property or services available for consumption or use by other persons (other than the grantor, individuals who are officers, employees, shareholders or members of the grantor, or persons related to the grantor or to such individuals), where supplies of the property or services made by the particular person to such other persons are exempt supplies, and (b) an amount of money paid or payable to the particular person by an organization (in this paragraph referred to as the "intermediary") that received the amount from a grantor or by another organization that received the amount from an intermediary, where i. in the case of an amount that, after 1990, becomes payable or is paid to the particular person, the intermediary or the other organization, as the case may be, provides to the particular person, at the time the amount is paid to the particular person, a certificate in a form prescribed by the Minister certifying that the amount is government funding, and ii. the amount would be government funding of the particular person because of paragraph (a) if the amount were paid by the grantor directly to the particular person for the same purpose as it was paid to the particular person by the intermediary or the other organization, as the case may be, and if the reference to "grantor" in subparagraph (a)(ii) included a reference to that intermediary or other organization, as the case may be. ...
GST/HST Interpretation

27 July 2012 GST/HST Interpretation 126511 - GST/HST Treatment of Retail Display Allowances

The Allowances paid to Retailers would generally be viewed as consideration for taxable supplies in respect of which GST/HST would generally be applicable, pursuant to section 165. However, if the Allowances meet the requirements of section 232.1, then they would not be regarded as consideration for a supply, and GST/HST would not apply. ...
GST/HST Interpretation

8 July 2010 GST/HST Interpretation 125382 - Services with Respect to Loan and Mortgage Applications

The XXXXX is an agreement between a lender and a borrower whereby the XXXXX (borrower) has executed a promissory note in consideration of the principal sum loaned by the XXXXX (lender). ... Specifically, the proposed amendment would not apply where, under a written agreement: • all of the consideration for the supply became due or was paid on or before December 14, 2009; • the supplier did not, on or before December 14, 2009, charge, collect or remit any amount as or on account of tax under Part IX in respect of the supply; and • the supplier did not, on or before December 14, 2009, charge, collect, or remit any amount as or on account of tax under Part IX in respect of any other supply that is made under the agreement and that includes the provision of a service referred to in paragraphs (q), (q.1) and (r.3) to (r.5) of the definition of financial service. ...
GST/HST Interpretation

17 February 2011 GST/HST Interpretation 129883 - Application of the GST/HST to certain services provided by investment dealers

Where, in consideration for a fee or commission paid by the investor to a dealer (e.g. a mutual fund dealer), the dealer provides a service of assisting the investor in purchasing, redeeming or exchanging units held in the investor's account, the service would generally be an exempt supply of arranging for a financial service. Whether services, for which consideration is a commission on the purchase of the units or a trailing commission, provided by a fund dealer to a fund manager or other third party are considered to be a single supply of a financial service is a question of fact. ...
GST/HST Interpretation

17 August 2004 GST/HST Interpretation 53462 - Effective date of Municipal Rebate at the Rate of 100%

XXXXX sets out the full consideration for the equipment as well as any services supplied to the individual, in the invoice made out to the individual. The individual pays part of the consideration to XXXXX and the XXXXX will cover the balance once the individual receives the equipment. ...
GST/HST Interpretation

29 June 2004 GST/HST Interpretation 52146 - Request for Designation as a "hospital authority" by the XXXXX

However, if we were to take that expense into consideration, the Land leases would nevertheless show a profit for each of the subject years. ... Other References: Policy P-167R, Meaning of the First Part of the Definition of Business, Policy Statement P-176R, Application of Profit Test to Carrying on a Business, XXXXX NCS Subject Code(s): 11950-1 2004/07/09 — RITS 52404 — [Liablility to Pay Consideration for Goods and Services Supplied by a Provider] ...
GST/HST Interpretation

21 December 2005 GST/HST Interpretation 49336 - Tax Status of Memberships

All possible benefits accruing to members must be taken into consideration in determining the tax status of a membership. ... Where the non-profit organization does not supply any property or services to non-members, then the discount is the difference in the consideration payable by the members for property or services and the fair market value of the property or services. ...
GST/HST Interpretation

11 April 2005 GST/HST Interpretation 53936 - GST Treatment of Personal Care Services

Interpretation Given Generally, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada tax in respect of the supply calculated at the GST rate of 7% (or HST rate of 15%, as applicable) on the value of the consideration for the supply. ... If after having considered its taste, ingredients, labelling and promotion, the product is a fruit-flavoured beverage, only the fruit juice content is taken into consideration when determining whether the 25% by volume threshold has been met. ...
GST/HST Interpretation

20 February 2006 GST/HST Interpretation 64222R2 - Review of GST/HST ruling XXXXX - Application of GST/HST to hotel accommodations

You are requesting that we review the GST/HST ruling XXXXX which found that your supplies of psychological assistant services to the psychologists XXXXX are taxable at the rate of 7% on the value of the consideration for these supplies pursuant to subsection 165(1) of the Excise Tax Act (ETA). After careful consideration of your arguments as well as a further review of the exempting provisions, we are confirming the GST/HST ruling that your supplies of psychological assistant services to the psychologists identified above do not fall within the exemptions in paragraph 7(j) or section 10 of Part II of Schedule V to the ETA. ...
GST/HST Interpretation

15 May 2007 GST/HST Interpretation 65393 - Redemption of Points at Retailer

Therefore, consideration paid to XXXXX in respect of the application process would be for "arranging for" a financial service as stated in paragraph (l) of subsection 123(1). XXXXX would not be required to collect GST/HST on the consideration received for this supply. ...

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