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Where a supply of TPP is made by way of sale, the place at which title of the TPP transfers is not the determinative factor in determining where the TPP is considered delivered or made available for purposes of paragraphs 142(1)(a) and 142(2)(a) of the ETA. 2. ... The CCRA's position with respect to where a supply of TPP by way of sale is considered to have been delivered or made available remains as set out in GST/HST Memoranda Series 3.3 Place of Supply. ... In any given case, the place where TPP is delivered or made available may be determined by reference to the place where it is considered to have been delivered under the law of the sale of goods applicable in that case. ...

Is the advance of money by XXXXX considered to be a financial service as defined within section 123(1) of the Act? ... Is the subsequent resale of inventoried property by XXXXX to third parties considered a taxable supply? ... A person who is considered to be a de minimis financial institution is subject to the special input tax credit rules. ...

As with food and beverages, it is also recognized that some products that would be considered to be ingredients by an average consumer have no nutritive value. ... This does not include some products commonly considered food that are often imported and sold as concentrated pastes (e.g. anchovy or tomato paste) in tubes. ... Therefore, algae in a liquid format would not be considered a "beverage". ...

Whether a person is resident in a particular place is a question of fact which can be decided only after all of these factors are considered and each is given its proper weight. XXXXX XXXXX and their families are generally considered residents of Canada for GST purposes and therefore are not eligible to claim a tax refund for visitors. ... In the meantime, XXXXX posted outside Canada are not eligible for the Visitor Rebate Program since they are not considered to be non-residents. ...

A person must first be considered a participant in a particular joint venture in order to be designated as its operator. ... These other responsibilities preclude the trust from being considered a bare trust for purposes of the Excise Tax Act. ... As a result, such a corporation would not be considered as a participant and thus, an operator, of the joint venture for purposes of the section 273 election. ...

Single ingredient salads which consist of one ingredient and a dressing or seasoning are also considered to be salads. ... Packages of ingredients must include a dressing or seasoning to be considered a salad. Where there is no dressing or seasonings applied to the other ingredients or supplied with or made available with the other ingredients, the supply is not considered a salad. ...

If the pet's owner does not accompany the pet on the flight, is the pet considered baggage or freight? ... The excess baggage charge made on a return leg of the round trip in question is considered to be in connection with the passenger transportation service. ...

Interpretation Given Scenario 1 You were inquiring as to whether brokerage services may be considered to be agency services. ... The rules for determining whether a supply is considered to be made in Canada are found in subsection 142(1) of the Act. For example, where goods are delivered or made available in Canada to the recipient, the supply will be considered to be made in Canada. ...

Both types of supplies are considered to be exempt of tax pursuant to section 8 of Part III of Schedule V to the Act. This is because the cost of dual and solo flying time up to the minimum flight training requirements to obtain a commercial pilot's licence is considered to be part of the student's tuition. ... Where the rental of the aircraft is considered to be part of the tuition, it is exempt. ...

If an organization (with no divisions) provides primarily secondary school courses but meets the requirements in both (a) and (b), can it still be considered to be a public college? ... In order to be considered a college, a facility must offer training or instruction in one or more occupations or professions and give degrees or diplomas. In order to be considered a technical institute, a facility must be a college that primarily offers courses in technical subjects. ...