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Accordingly, the goods would not yet be considered to be for use in the commercial activity of the resident and the resident would not be entitled to claim the ITCs for the tax paid at time of importation. ...

XXXXX We concur with this position that a person should not be considered a "supplier" on the basis that the person issues an invoice to a recipient of a supply. ...

It is at this point in the transaction cycle that the rules of section 181 would be considered. ...

It is the Department's position that a person will be considered and treated for GST purposes as an agent based on fact and the principles of law. ...

As explained below, the Chamber is considered to have contracted out/purchased the services from XXXXX and then resupplied them to its course participants. ...

Other Secondary Issues Although the explanation for the interpretation of the primary issue is provided above, explanations of the transactions before and after the swaps give rise to secondary issues that must be considered to keep the whole set of transactions in perspective. ...

The XXXXX agents are not considered to have paid an amount as tax in error that would give rise to a rebate under section 261 of the Excise Tax Act. ...

Registrant's Position The distribution fees are exempt since the services provided should be considered independently. ...

Response As stated in section 191 of the ETA, substantial completion in respect of substantial renovation is considered to occur when the construction is 90% completed in a physical sense, but the valuation to be used is 90% of the fair market value of the addition. ...

In other words, the trailer park will not be considered a residential trailer park if the operators of the trailer park make lease agreements for a period of one month, or for periods of more than one month and less than twelve months. ...