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Establishing the City's ITC eligibility requires determining whether the supply of the XXXXX Assets made by the City to the Utility pursuant to the Sublease is a taxable supply for GST purposes (The City is considered to have acquired the XXXXX Assets (under the Head Lease) for the purpose of making a supply of those assets (under the Sublease). ...

As a result the Organization will be considered an NPO for purposes of section 259 where it meets the definition of NPO in subsection 123(1) when read without reference to a government. ...

To be considered a residential unit in this case, the room in the hospital must meet one of the "structural" components described in paragraphs (a) to (c) as well as one of the "functional" components in paragraphs (d) to (g). ...

However, in order for the event to be considered a related convention supply, the client would be required to provide detailed information justifying the nature of the supply as one that is not excluded from the definition. ...

Under common law, an agent is considered to represent the principal such that it can affect the principal’s legal position, such as through the disposition of property. ...

RULING REQUESTED You would like to confirm that: 1. payments received by the Association from Partners that participate in the Program and who offer reward dollars to Association members represent consideration for the supply of a gift certificate and, as such, the Association is not required to collect GST/HST on the supply of the reward dollars; 2. when reward dollars are used by members to purchase property and services, the Association should treat the reward dollars as money; and 3. if the reward dollars are not considered a gift certificate, the non-reimbursable coupon rules in subsection 181(3) apply in situations where the Association treats the reward dollars as a “partial cash payment that does not reduce the value of the consideration for the supply” so as to allow the Association to claim an input tax credit (ITC) for the tax fraction of the reward dollars. ...

Whether services provided under agreements are considered to be a single supply or multiple supplies is a question of fact. ...

In determining if a service is included in paragraph (l) of the financial service definition, all of the facts surrounding the transaction must be considered. ...

As a result, supplies of property or services made by [Corporation A] that are currently considered exempt pursuant to section 1 of Part V.1 of Schedule V (general exemptions for charities) would generally become taxable supplies pursuant to paragraph (n) of section 2 of Part VI of Schedule V, unless another exemption is available. ...

RULING REQUESTED You would like to know whether the two individuals are considered to be partners of a partnership, and whether each of the two individuals has to file UHT returns for the residential property. ...