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Pursuant to section 175, the charity is deemed to have received a supply of the car rental, and the use of the car by the volunteer for the two days is considered to be use by the charity. ...

In addition, the T2200 and T777 would only apply to situations where the shareholder is also considered an employee of the corporation. ...

As the agent can recover the respective portions of the remittance from the other dentists, we consider that the agent is being reimbursed for amounts it pays on behalf of these other dentists, who would be considered to be principals. ...

. … Consequently, the Assignee is not considered the recipient of the supply of software licences and is not entitled to claim an ITC for the GST/HST paid for them to the Vendor. ...

Would such supply be considered to be made outside Canada by virtue of s. 144? ...

Given that a qualifying subsidiary of a qualifying subsidiary of the particular corporation is also a qualifying subsidiary of the particular corporation, C3 (applying this rule iteratively) is considered to be a qualifying subsidiary of Hold Co, as is C4. ...

For voluntary registration, the effective date of registration is usually the date the person's application is considered to be received by the CRA (for example, when an application is mailed, the post-marked date). ...

Applying the contextual modifications that are necessary to give effect to the reference in subsection 15(2.192) to the “specified right” definition in subsection 18(5), where a financial institution lends money on commercial terms to an individual that is a shareholder of a corporation, the corporation provides a security interest in its property to the lender, and such property can only be used in the event of default on the loan as a means of repaying amounts owing by the debtor under the lending agreement, then the security interest would not ordinarily be considered a “specified right”. ...

CRA stated: The CRA’s position has been that where a registered supplier supplies goods on a delivered at destination basis and the terms for the sale of the goods dictate that the supplier must deliver the goods to a destination specified by the recipient, the delivery of the goods will generally be considered to be part of a single supply. ...

This rule would normally apply as the corporations would not be considered to be dealing at arm’s length and the recipient may not be a registrant using the goods exclusively in commercial activity. ...