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Where the "importer of record" is a person who is only acting on behalf of the lessee, the owner or the lessor for the importation of the goods, the goods will be considered to have been imported by the lessee, the owner or the lessor and not by the "importer of record". ... In the case described above, the equipment is considered to be a Canadian good as it was manufactured in Canada by a division of CoC for CoC's consumption, use or supply and CoC has legal title to the equipment. ... Response Goods manufactured in Canada are considered to be Canadian goods. ...

As a result, any person who is a GST/HST registrant that does not have managerial or operational control of the joint venture including a person referred to as a nominee corporation or bare trust will not be considered a participant for purposes of section 273 and, therefore, cannot be considered an operator of the joint venture. ... In the scenario, the nominee corporation's functions are not significant enough to be considered as having the managerial or operational control of the joint venture. ... Therefore, the nominee corporation is not considered to have the managerial or operational control of the joint venture and thus cannot be considered a participant in the joint venture. ...

You stated in your incoming fax that: […] RULING REQUESTED You would like to know: Is the CEWS considered to be government funding as defined in section 2 of the Public Service Body Rebate (GST/HST) Regulations? ... Since the CEWS is not government funding, it is not considered in element A in the denominator or the numerator of the formula. ... The CEWS is not considered a gift either because it is not a voluntary payment for no consideration. ...

Excise and GST/HST Rulings Directorate Legislative Policy and Regulatory Affairs Branch 10-320 Queen Street, Tower A Ottawa, ON K1R 5A3 [Addressee] Case Number: 209955 [Dear Client] Subject: [GST/HST Interpretation] [Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] We are writing in response to your [correspondence] of May 25, 2020, wherein you request that we rule on whether the […][Canada Emergency Wage Subsidy (“CEWS”)] and […][10% Temporary Wage Subsidy for Employers (“TWS”)] programs are considered government funding for purposes of the Public Service Bodies’ (“PSB”) Rebate. ... Although the TWS is considered government assistance for income tax purposes and must be included in computing taxable income, the TWS is not government funding as defined in section 2 of the Public Service Body Rebate (GST/HST) Regulations. ... Therefore, the TWS cannot be considered an amount of money that is paid or payable to the particular person (the eligible employer) by a grantor. ...