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In the example described in your letter where two properties valued at $6 million and $10 million, owned by A and B respectively, are exchanged with an additional cash transfer of $4 million from A to B to offset the difference, for GST/HST purposes, two supplies are considered to have been made: 1) One supply from B to A of a $10 million property. ...

The transfer of the land title by XXXXX to XXXXX is considered, in these circumstances, to be a supply made for nil or nominal consideration. ...

While no particular factor is determinant in itself, the following factors are considered: •   the purpose/mandate of the organization/program as set out in its governing documents, •   how the supply is promoted or advertised, •   nature/design and use of facilities, •   proportion of staff time devoted to one activity over another, •   proportion of program schedule devoted to one activity over another, •   proportion of class/session devoted to one activity over another, •   extent of use of assets/resources/overhead to one activity over another, •   motivation of participants to register for program, •   can an individual receive care and supervision only, and if so, what proportion of participants receive only care and supervision, •   qualifications of staff. ...

Analysis As indicated in your letter, under Policy Number P-083 the transaction contemplated by the Purchase Agreement would be considered to be the single supply of a residential complex by way of sale. ...

In reviewing your request, it was unclear at that time whether this sale by XXXXX which would have been considered a commercial activity for GST/HST purposes if found taxable, was in conflict XXXXX[.] ...

However these supplies will remain exempt if the value of the admission, discount or right is considered "insignificant" in relation to the consideration for the membership. ...

If the first ground station is located in Canada, the telecommunication is considered to be emitted in Canada. ...

If you have any questions concerning whether certain services are considered to be hospital activities, presumably for purposes of the rebate, please provide us with details. ...

Based on the facts provided, most of the purchases made with respect to the activities of the Project are made from the Project funding which is considered to be funding received by XXXXX on behalf of the Project. ...

The following examples illustrate how the conditions in paragraphs (j) and (j.1) must be considered to determine the tax status of a particular supply of a service of providing an appraisal. ...