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" Therefore, we must determine whether a Homeowner who enters into the Construction Contract with the Contractor to construct a house on the Home Site is considered to have "engaged" the Contractor to construct a SURC. ... As such, a Homeowner would be considered to have engaged the Contractor to construct a SURC if the Homeowner enters into the Construction Contract with the Contractor to construct a house on the Home Site that the Homeowner had acquired by way of sublease from the Corporation. ...

Under the provisions of 199(2), a charity that uses capital real property primarily in commercial activities is considered to use such property exclusively in commercial activities. ... Supply to Government In some circumstances, a fair and reasonable manner to determine the extent to which improvements are considered to be for making a supply to the landlord would be based on that portion of the tenant's cost of making the improvements that is reimbursed by the landlord. ...

Generally, a financial institution would be considered to be a selected listed financial institution (SLFI) throughout a reporting period in a fiscal year that ends in a particular taxation year of the financial institution, if the financial institution is a listed financial institution described in any of subparagraphs 149(1)(a)(i) to (x) at any time during the particular taxation year, and the financial institution has a permanent establishment in a participating province and a permanent establishment in any other province, at any time during the taxation year. ... The facts and circumstances of each transaction would have to be considered on their own merits. ...

Subsection 3(1) of the IFTA Reg. states: "for the purposes of subsection 4.13(1) of the Act, a licencee, when operating an inter-jurisdictional vehicle, is considered to be registered with the Minister, but only if the licencee, (i) affixes the registration decals or carries a 30-day IFTA temporary permit issued by a base jurisdiction other than Ontario as required under Part VI of the Articles of Agreement under the IFTA; and (ii) places in the motor vehicle the IFTA licence issued to the licencee, or a legible copy of the licence, as required under Part VI of the Articles of Agreement of the IFTA. ... Reg. 22/97, a carrier is considered registered with the Minister for purposes of the regulatory framework and the IFTA, only if it displays a registration certificate and a set of decals in each qualifying vehicle. ...

Gross revenue includes business income, donations, grants, gifts, property income, investment income and any amount considered a capital gain less any amount considered a capital loss from the disposal of property for income tax purposes. ...

Rather, the certificates entitle the purchaser to monetary discounts and offer items for no charge if another item is purchased; therefore, the certificates are not considered to be gift certificates. ... As the certificates do not offer a reduction equal to fixed dollar amount or fixed percentage amount, the certificates are not considered to be "non-reimbursable coupons" under subsection 181(3). ...

The copies of digital images on CD are considered to be a supply of tangible personal property. ... Multiple supplies may also take the form of a single transaction, but the constituent elements are considered separate supplies. ...

Generally, supplies of services for which an agent charges a commission are considered to be relating to the supply of tangible personal property to the recipient. ... Agency relationships Whether there is an agency relationship between two parties with respect to a particular transaction is a question of fact; however, the following are considered to be essential qualities of an agency relationship: 1. ...

An entity that does not meet all of these requirements will not be considered to be making facility supplies and therefore would not qualify as a "facility operator". ... Since XXXXX does not make facility supplies, the facts respecting the receipt of government funding have not been considered for purposes of determining whether it meets the other requirements with respect to qualifying facilities. ...

The factors that will be considered in determining whether a non-resident person is carrying on business in Canada for GST/HST purposes in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ... Generally, a non-resident person must have a significant presence in Canada to be considered to be carrying on business in Canada. ...