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Indicated below are the scenarios and our opinion as to whether the bare trustee or the beneficial owner(s) should register, given that the consideration for taxable supplies would have exceeded $30,000 in the prior four consecutive calendar quarters. 1. ...

Notwithstanding that the information is supplied for no consideration, it is still a "supply" within the meaning of that term in subsection 123(1). ...

Statement of Facts: In your memo you provide the following facts for our consideration: •   "A" Ltd. is a Canadian corporation and a GST registrant with approximately XXXXX commissioned sales employees and non-commissioned service employees. •   To compensate these employees for use of their personal vehicles, A Ltd. pays a per kilometre allowance. •   Amounts in respect of the allowance are deductible in computing A Ltd.'s income for income tax purposes. •   A Ltd.'s compensates their employees for using their personal vehicles in the course of their employment through a dual rate plan. ...

With this in mind, the central issue to be addressed in this case (which is advanced in the above questions for our consideration) is whether the various per kilometre motor vehicle allowances paid to employees are all treated as reasonable allowances for income tax purposes. ...

Therefore, if the sale of the real property pursuant to the order of the Court was a supply within the scope of subsection 183(3) of the Act, then there would be a loss of revenue to the Crown equal to 7 percent of the value of the consideration less the GST new housing rebate, if any, that would be payable to the purchaser(s) in respect of the complex pursuant to subsection 254(2) of the Act. ...

After consideration of all the criteria, the supply of management services should best be considered a single supply. ...

After consideration of all the criteria, the supply of management services should best be considered a single supply. ...

Subsequent to our meeting, additional information concerning the implementation of the cost-recovery initiative in question was submitted for our consideration. ...

" Therefore, for purposes of the XXXXX, a nursery school is considered a day care facility. (4) During your telephone conversation with Don Dawson on October 25, 1994, you confirmed that the organization is not a charity or a school authority as defined in subsection 123(1) of the Excise Tax Act (ETA). (5) You indicated in your telephone conversation with Don Dawson on December 2, 1994, that the Pre-school issues child care income tax receipts for fees charged as consideration for the supply of the service. ...

We have also taken into consideration the Supreme Court cases that you have cited. ...