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The place of supply rules set out in the Regulations apply to any supply made on or after May 1, 2010, and any supply made after February 25, 2010 and before May 1, 2010, unless any part of the consideration for the supply becomes due or is paid, before May 1, 2010. ... Smith Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate Enc.: GST/HST Memorandum 1.4, Excise and GST/HST Rulings and Interpretations Service i 1 Under subsection 123(1) of the Act, the recipient of a supply is generally the person who is liable to pay the consideration payable for the supply under the agreement for the supply.------------------------------------------------------------------------------------------------------------------------------------------------------ UNCLASSIFIED ...

Whether a particular non-resident person is carrying on business in Canada is a question of fact requiring consideration of all relevant facts. ... As previously indicated, the determination of whether a person is carrying on business in Canada for GST/HST purposes is a question of fact requiring consideration of all relevant facts. ...

Conversely, if the supply by the non-resident person were made in Canada and does not qualify for zero-rating, the Canadian sales representative would be required to charge the GST/HST on the consideration payable for her service. ... With respect to your second question, the method by which the consideration for the supply is determined (i.e., commission or flat fee) would not affect the zero-rated status of the service provided the conditions for zero-rating the supply under section 5 of Part V of Schedule VI are met. ...

The payments from the XXXXX to developers for the cost of qualifying infrastructure works supplied to the City are considered to be consideration for taxable supplies of services, from the developers to the City. The payments from the XXXXX to the developers for the cost of the underlying land transferred to the City are considered to be consideration for taxable supplies of real property, from the developers to the City. ...

The reservation fee payable to XXXXX It is our understanding that this fee is consideration for a supply made by XXXXX to the Club's members. ... A reservation fee may be consideration for a supply of a service. The relevant place of supply provisions are paragraphs 142(1)(d), 142(1)(g), 142(2)(d) and 142(2)(g). ...

., a personal emergency response system), •   an on-site nurse manager and at least one nurse on duty 24 hours per day to respond to emergency situations, •   activity programs tailored to the needs of the Residents, •   weekly housekeeping services including a change of bed linens and towels, and •   one dinner served daily that takes into consideration special dietary needs of the Residents. 8. The XXXXX package includes the items delineated in XXXXX to the Tenancy Agreement (attached as Appendix 1 of your submission) and in the "XXXXX Information Package" (attached as Appendix 2), namely: •   a specific suite and the property and services indicated in Fact 6, •   call-bell monitoring, •   an on-site nurse manager and at least one nurse on duty 24 hours per day to respond to emergency situations, •   activity programs tailored to the needs of the Residents, •   administering medication to residents on an as-needed basis, •   daily light housekeeping and weekly housekeeping services including a change of bed linens and towels, •   assistance with bathing once a week, and •   three meals daily (that take into consideration special dietary needs of the Residents) and meals delivered to a Resident's room when authorized by the nursing manager. 9. ...

XXXXX conveyed these lots for consideration equal to the pertinent legal expenses and survey costs. ... XXXXX the Estate entered into an agreement of purchase and sale of XXXXX with XXXXX (the "Association"), a non-registrant, for consideration equal to $XXXXX. ...

X will transfer title to the original parcel to his spouse and himself as joint tenants for no consideration. 5. ... The land continues to be used solely in the farming operation as it was prior to the transfer into joint tenancy. •   The consideration paid by the non-farming joint tenant to effect the transfer is nil or a nominal amount. •   The non-farming joint tenant is not currently registered and the only reason the non-farming joint tenant would otherwise register would be to avoid the effect of section 155. •   The non-farming joint tenant does not receive any proceeds from the farming business that are business income earned on the individual's own account for income tax purposes. •   The individual who operates the farm must transfer the farmland into joint tenancy with himself/herself and one or more "related person", as defined in subsection 126(2), which would include the individual's spouse. •   The non-farming joint tenant is not involved in the farming business independently of the individual's own account and the farming operation is not a partnership. ...

The amendment applies to any supply for which consideration becomes due after March 9, 2004, or is paid after that date without having become due. ... Any supply made under the new lease agreement will not be exempt under section 25 of Part VI of Schedule V if the consideration for the supply becomes due after March 9, 2004, or is paid after that date without having become due. ...

Statement of Facts: In your memorandum you provide the following facts for our consideration: 1. ... Paragraph 54(d) of the Income Tax Act defines "eligible capital property "as "any property, a part of the consideration for the disposition of which would, if the taxpayer disposed of the property, be an eligible capital amount in respect of a business. ...