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The position presented by XXXXX, after their analysis of the facts, as they perceive them, within the framework of Policy P-077R " Single and Multiple Supplies ", is interesting from a discussion point of view but we cannot accept its conclusion that all administrative services within any mortgage securitization program should be considered to fall within the definition of financial services and therefore be exempt of tax. ...

Where a member of a partnership acquires or imports property or services related to the raising of funds, negotiation or legal services that the member will use to acquire or maintain an interest in a partnership, such property or services will not be considered to have been acquired or imported for consumption, use or supply in the course of activities of the partnership. ...

The determination of whether GST or HST applies to the supplies made by XXXXX to XXXXX depends on where those supplies are considered made, which in turn depends on the type of supplies being made. ...

The question here is whether the visitation can be considered to be a memorial or final service. ...

A diagnostic service is considered to be the detection and determination of the cause of a disease by means of a study procedure and the report of findings. ...

However, when the operator bundles these goods and services together and renders them as a "package" to the facility's patients, this package is considered to be a composite exempt supply of an institutional health care service. ...

Under this provision, a supply of IPP is considered to be made in a province if the place of negotiation of the supply is in the province, and the IPP may be used otherwise than exclusively outside the province. ...

Accordingly, the transfer is not considered to be a voluntary transfer under subsection 183(9), but a sale for consideration. ...

These factors should be considered in the course of conducting an analysis in determining whether a supply constitutes an admission or a service. ...

Although the airline did not actually render the service, the airline is nevertheless considered for GST purposes to have supplied the service when the ticket was purchased. ...