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To be considered incidental, a supply generally plays only a minor or subordinate role in relation to the provision of another supply. 31. ... In determining whether a particular supply is a supply of intangible personal property or a supply of a service, a number of factors must be considered such as: the nature of the agreement between the supplier and the recipient whether the agreement is in substance for work (or work and materials), or for property (including a right or interest of any kind) 44. ... In these cases, there is a specific place of supply rule that may apply and that should be considered first. ...

A trust will not be considered an alter ego trust if it so elects in its T3 return for its first tax year. ... Related persons are not considered to deal with each other at arm’s length. ... Payment for unused sick leave is considered a death benefit and is income of the estate or beneficiary who receives it. ...

Consideration is considered to be "paid" when the supplier receives the money, property or service which is consideration for the supply. ... Under this broad definition, any record of a supply which sets out the goods or services which make up the supply, along with the consideration due or paid for the supply, will be considered to be an invoice. ... Where a person gives a deposit in respect of a supply, (other than an amount in respect of a covering or container in respect of which section 137 applies to deem the covering or container to be part of the property supplied), that deposit is not considered to be consideration for the supply unless and until the supplier applies the deposit against the consideration for the supply or the deposit is forfeited. 43. ...

Where a full ITC is not available to the recipient, the transaction will not be considered a wash transaction. ... The waiver of penalty and interest in excess of 4% of the tax not properly charged or the ITCs not properly accounted for in a wash transaction will normally be considered automatically by the CRA during the audit process. ... The waiver of interest in excess of 4% of the tax not properly charged in a wash transaction will normally be considered automatically by the CRA during the audit process. ...

Changes in use of capital property that are insignificant are not considered to be changes in use for the purposes of the Act. ... Where such changes of less than 10 per cent accumulate to 10 per cent or more, the accumulated changes are considered to be a significant change, invoking the change in use rules. ... The registrant is considered to have sold the computer at its fair market value at that time. ...

A stop between two legs of a journey that is 24 hours or less is not considered to be a stopover. However, a stop of more than 24 hours between two legs of a journey will generally be considered a stopover where two or more tickets or vouchers are issued for the legs of the journey. ... Therefore, each ticket has to be considered separately to determine whether GST or HST applies. ...

Software supplied on a carrier medium is considered to be a supply consisting of the physical carrier medium (e.g., the disk) and the software stored on the disk (e.g., the instructions). ... Tax Treatment of Licensed Custom Software Tax Treatment Under Division II Under subparagraph 142(1)(c)(i) of the Excise Tax Act, a supply of intangible personal property is considered to be made in Canada if the property may be used in whole or in part in Canada and: the recipient is a resident in Canada or registered for theGST; and the supplier, even if a non-resident, is registered for the GST. ... Other Imported Computer Software Arrangements Electronic transmission of software A supply of computer software that is transmitted electronically is considered to be a supply of intangible personal property. ...

The Agency is strengthening its governance over learning through the introduction of new directives and guidelines that will be considered by the Board at its meetings in June. ... Response In 2008-09, the internal mobility rate (including promotions, transfers and lateral moves) was of 21. 6% in the CRA a level considered to be indicative of sound learning and development. ... Key Questions 1: What processes are in place to ensure that the workplace is safe and that employees' health and wellness are being considered? ...

In cases where a supply is made for more than one purpose, all of the purposes would be considered when determining if the supply is a qualifying health care supply. ... Every combination of eligible corporations or eligible Canadian partnerships whose names appear in Part A of the form (and on any attached page) is considered to have made the election. ... Licensees’ returns must be filed up-to-date to be considered for semi-annual filing. ...

GST/HST issues Generally, fundraising by its very nature is considered a profit activity. Organizations that are established and operated for the sole purpose of raising funds are not considered non-profit organizations for GST/HST purposes, even if all the profit from a fundraising activity is donated to a registered charity. ... Income tax issues As previously mentioned, fundraising by its very nature is generally considered a profit activity. ...