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The Acknowledgement Agreement also provides that in consideration of [CCo] providing financial assistance to [BCo] and for other valuable consideration, the receipt and sufficiency of which is acknowledged, [BCo] acknowledges and agrees that the Term Sheet and all terms and conditions thereof will continue in full force and effect notwithstanding the advance of the Loan by [CCo] and will govern the relationship between [CCo] and [BCo] in relation to the Loan as if the Term Sheet were a loan agreement entered into at the time of the advance of the Loan. 11. ... RULING GIVEN Based on the facts set out above, we rule that the Commitment Fee was consideration for [ACo]’s supply of a financial service which was exempt under section 1 of Part VII of Schedule V to the ETA. ... The Commitment Fee is consideration that was paid for this exempt supply. ...

The reimbursements of the Employees’ remuneration under the Cost Sharing Arrangement by Company B and Company C will not be consideration for taxable supplies made by Company A to Company B and by Company A to Company C. ... EXPLANATION Section 165 states that every recipient of a taxable supply made in Canada shall pay GST/HST on the value of the consideration for the supply. ... Where an agent remunerates a principal’s employee, the amount of money the principal pays the agent as a reimbursement for the employee’s wages is not consideration for a supply and therefore is not subject to tax. ...

EXPLANATION 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, […] Under the ITA, the CEWS takes the form of a deemed overpayment of liability under Part I of the ITA by an eligible entity, which is then refunded to the eligible entity. ... The Queen, 2015 TCC 278, in which the Court stated “funds received by a non-profit operator of an assisted living or residential care facility from a grantor as consideration for making such property and services available for consumption or use by the residents of the facility would still fall within the definition of “government funding” in the [Public Service Body Rebate (GST/HST) Regulations]…” Even if the CEWS were not considered a refund of taxes, the CEWS is not consideration for a supply. ... The CEWS is not considered a gift either because it is not a voluntary payment for no consideration. ...

Instead, HST applies to the supply of a right to acquire a membership if the consideration for the supply becomes due, or is paid without having become due, on or after July 1, 2010. Based on the information provided, the entrance fee charged by the Club is not consideration for a supply of a membership, lifetime or otherwise. Rather, the entrance fee is consideration for a right to acquire a membership, and therefore, the transitional rules for supplies of intangible personal property will apply. ...

However, the payments from the Fund to XXXXX are grants, and not consideration for supplies. ... As indicated in the above-noted ruling, the payment from the Fund to XXXXX is a grant and not consideration for a supply. ... Therefore, the reimbursements received from the shareholders are consideration for taxable supplies. ...

This is a single supply of personal property made for the consideration of the registration fee. ... The working breakfast is a single supply of personal property made for the consideration paid for the ticket. ... "an admission in respect of a "place of amusement" unless the maximum consideration for a supply by the charity of such an admission does not exceed one dollar. ...

The application of section 9 of Part II of Schedule V to a particular supply is dependent on the mechanism under which the consideration, or portion thereof, payable or reimbursable is made for that supply. Therefore, it will be a question of a fact as to whether the consideration, or a portion of the consideration, payable for a particular service (whether massage therapy or Osteopathic manual therapy) supplied by XXXXX is paid under a provincial health insurance plan described in this exempting provision; i.e., the XXXXX Plan. ... The tax is collectible and remittable on the value of the consideration charged for taxable supplies of both Osteopathic manual therapy services and massage therapy services. ...

As such, the consideration paid to XXXXX is subject to GST under subsections [sic] 165(1) of the ETA. ... The reimbursements of the salaries and wages would form part of the consideration for the supply. ... These reimbursements would be part of the consideration for the supply of management services by XXXXX to XXXXX. ...

Subsection 152(2) of the Act states that where property is supplied by way of lease, licence or similar arrangement under an agreement in writing, the consideration, or any part thereof, for the supply shall be deemed to become due on the day the recipient is required to pay the consideration or part to the supplier pursuant to the agreement. Subsection 168(2) of the Act states that where consideration for a taxable supply is paid or becomes due on more than one day, the tax in respect of the supply is payable on each day that is the earlier of the day a part of the consideration is paid and the day that part becomes due and the tax that is payable on each such day shall be calculated on the value of the part of the consideration that is paid or becomes due, as the case may be, on that day. ... Amounts applied to the invoiced "remedy of repudiation" will be deemed, pursuant to s. 182 to be comprised of consideration and tax. ...