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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. ...

Bitcoin Mining before February 5, 2022 Prior to February 5, 2022, where a person performs a mining activity of validating transactions and adding them to a publicly distributed ledger as a solo miner, the provision of those activities would be considered a taxable supply for GST/HST purposes. ...

Subsection 141.01(2) provides that the extent to which a property or service is considered to be acquired for consumption or use in a person's commercial activities is generally based on the extent to which the property or service is acquired for the purpose of making taxable supplies for consideration. ...

Cryptoasset Mining before February 5, 2022 Prior to February 5, 2022, where a person performs a mining activity of validating transactions and adding them to a publicly distributed ledger as a solo miner, the provision of those activities would be considered a taxable supply for GST/HST purposes. ...

To arrive at this conclusion, we considered information obtained from your letters, our telephone conversation, and the Agreement you enter into with your clients. ... There are numerous work elements, such as training or instruction, included as part of this overall supply of services, however, we do not consider that these individual tasks or elements carry sufficient weight on their own to warrant being considered separate supplies. ...