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As such, this benefit could not be considered a secondary or unintended consequence of membership and is therefore not an indirect benefit. ...

However, if Corp A does not claim the ITC, Corp D, who is the importer of record and thus has the import documentation, will instead be considered as having imported the goods for supply in the course of its commercial activities, for purposes of subsection 169(1). ...

Therefore, we are of the view that the products previously referred to in paragraphs 6a), b), c), f), g) and h) are considered food and are zero-rated for GST/HST purposes, as none of the exceptions of Part III apply. ...

As such, this benefit could not be considered a secondary or unintended consequence of membership and is therefore not an indirect benefit. ...

The property and services listed in Ruling 3 are not considered to relate to the occupancy or use of a residential condominium unit in the Condominium and accordingly, are not exempt under section 13 of Part I of Schedule V to the ETA. ...

A facility or part of a facility will be considered a qualifying facility if: (a) supplies of services that are ordinarily rendered during that fiscal year or part to the public at the facility or part would be facility supplies if the references in the definition of "facility supply" in subsection (1) to "public hospital or qualifying facility" were references to the facility or part; (b) an amount, other than a nominal amount, is paid or payable to the operator as qualifying funding in respect of the facility or part for the fiscal year or part; and (c) an accreditation, licence or other authorization that is recognized or provided for under a law of Canada or a province in respect of facilities for the provision of health care services applies to the facility or part during that fiscal year or part. ...

In the case of the Joint Venture, if: the BTA between NomineeCo, Company X and Company Y is indeed a true bare trust arrangement; Company X has a beneficial ownership interest in the Joint Venture Lands; Company X is elected operator of the Joint Venture; and Company X will engage persons under, or by way of, supplier agreements to construct the Units; then Company X would meet the definition of "builder" as Company X would be considered to be carrying on, or engaging another person to carry on for Company X, the construction of the Units while it has an interest in the Joint Venture Lands. ...

The joint venture policy states that "Where, however, an agency relationship does not exist when the non-electing participant's share of the joint venture product is sold the non-electing participant would be considered to be making a supply to the recipient of the product equal to its interest in the product as determined by the joint venture agreement. ...

The supply of residential units to tenants other than on a rent-geared-to-income basis such as the supply of residential units at the full rental rate, commercial leases of space, etc. are not considered to be supplies of municipal services for purposes of subsection 259(1) of the Excise Tax Act and, therefore, organizations supplying these services will not be designated as municipalities with respect to these supplies. ...

As such, a trust created under an agreement entered into between XXXXX and its employees is considered a separate person for purposes of GST. ...