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For purposes of section 137 of the ETA, the XXXXX is not considered to be a usual covering or container. Further, the supply of the XXXXX and XXXXX is considered a single supply for purposes of the ETA. ... All coverings or containers for zero-rated basic groceries which are generally recognized as containers in their own right are considered to be usual coverings or containers under section 137. ...

In particular, you wish to know whether the fares charged in XXXXX XXXXX can be considered to be regulated under the laws of Canada or a province, as required in the definition of "taxi business" found in the ETA. ... " Here, the province of XXXXX has delegated its authority to regulate taxi fares to XXXXX XXXXX When a province delegates its power to regulate fares to municipalities, this is considered to be the regulation of fares "under the laws of... a province", as required. ... Thus taxi fares in XXXXX are considered to be regulated under the laws of a province whether or not the City has passed a by-law on the subject of taxi fares. ...

XXXXX is concerned that the above reference to "branch or division" may be interpreted by Revenue Canada such that supplies of telecommunication services, electricity, gas or steam between branches or divisions of the same municipality would be considered taxable supplies. ... Supplies within a municipal entity of telecommunication services, electricity, gas or steam, such as supplies between branches or divisions of a municipal corporation are not considered to be supplies for Goods and Services Tax (GST) or Harmonized Sales Tax (HST) purposes. Since no supply is considered to have been made, there are no GST implications. ...

Consequently, for GST purposes, property used 90% or more in the course of a commercial activity is considered to be used exclusively in the course of a commercial activity, and property used less than 90% in the course of a commercial activity is considered to be used otherwise than exclusively in the course of a commercial activity. ... Interpretation Given For the purpose of subsection 3(2) of the Joint Venture (GST) Regulations, to determine whether property is used exclusively in the course of a commercial activity, the use of the property should be considered over a period of time which is appropriate in the circumstances. ...

You have also inquired whether the XXXXX is considered to be a donation by XXXXX to the NPO. ... In order for any gift to be considered a tax deductible donation under the Income Tax Act, it must be made to a registered charity. There is no indication that the NPO is a registered charity thus the XXXXX cannot be considered a donation for Income Tax purposes. ...

You had enquired with the PST department who advised you your supply would be considered exempt for provincial tax purposes. You therefore, wish to confirm that the GST would also be considered exempt where a non-Indian contractor purchases XXXXX for use and consumption on reserve. ... If however, the Indian contractor has an incorporated business, goods purchased are subject to tax as a corporation is considered to be a separate legal person from an Indian. ...

A combination of one ingredient mixed with a dressing or seasoning(s) that is sold or represented as a salad is also considered to be a salad. Fruit salads and gelatine salads generally do not need a dressing to be considered a salad. ... Although no one factor is determinative on its own, there are several factors which, when considered together, indicate that the Product is a salad. ...

Whether a person is considered to be an agent for GST/HST purposes is based on a determination of fact and an application of principles of law. ... Generally, an agent will be considered to be independent if the agent is both legally and economically independent of the principal on whose behalf the agent is acting. ... Therefore, USCo would not be considered to have a permanent establishment in Canada under paragraph (b) of the definition of "permanent establishment". ...

. •   The products are considered TPP for GST/HST purposes. •   XXXXX sells its products to XXXXX with the following terms of delivery: i. ... 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. ... " such as the XXXXX contract does, delivery of the TPP to the purchaser is considered to take place outside Canada at its warehouse when the supplier gives the goods to the carrier for shipment to the purchaser. ...

Further, they are considered to be "sold in single servings" if they are designed and marketed for sale as single servings. ... Where a product is not designed and marketed for sale in single servings it is not considered to be "sold in single servings". As the product in question is not individually wrapped it is not considered "packaged in single servings"; as it is not designed and marketed for sale in single servings it is not considered to be "sold in single servings". ...