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GST/HST Interpretation

2 April 2001 GST/HST Interpretation 33358 - GST Implications of Canadian Goods Returned as Described in Customs Notice N-118: Tax Treatment to be Accorded to Imported Goods Considered to be Canadian Goods and Goods Once Accounted for, Exported, and Returned

Where the "importer of record" is a person who is only acting on behalf of the lessee, the owner or the lessor for the importation of the goods, the goods will be considered to have been imported by the lessee, the owner or the lessor and not by the "importer of record". ... In the case described above, the equipment is considered to be a Canadian good as it was manufactured in Canada by a division of CoC for CoC's consumption, use or supply and CoC has legal title to the equipment. ... Response Goods manufactured in Canada are considered to be Canadian goods. ...
GST/HST Interpretation

21 January 2013 GST/HST Interpretation 146302 - Whether a Nominee Corporation Can Be Considered the Operator of a Joint Venture

As a result, any person who is a GST/HST registrant that does not have managerial or operational control of the joint venture including a person referred to as a nominee corporation or bare trust will not be considered a participant for purposes of section 273 and, therefore, cannot be considered an operator of the joint venture. ... In the scenario, the nominee corporation's functions are not significant enough to be considered as having the managerial or operational control of the joint venture. ... Therefore, the nominee corporation is not considered to have the managerial or operational control of the joint venture and thus cannot be considered a participant in the joint venture. ...
GST/HST Interpretation

22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]

Excise and GST/HST Rulings Directorate Legislative Policy and Regulatory Affairs Branch 10-320 Queen Street, Tower A Ottawa, ON K1R 5A3 [Addressee] Case Number: 209955 [Dear Client] Subject: [GST/HST Interpretation] [Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] We are writing in response to your [correspondence] of May 25, 2020, wherein you request that we rule on whether the […][Canada Emergency Wage Subsidy (“CEWS”)] and […][10% Temporary Wage Subsidy for Employers (“TWS”)] programs are considered government funding for purposes of the Public Service Bodies’ (“PSB”) Rebate. ... Although the TWS is considered government assistance for income tax purposes and must be included in computing taxable income, the TWS is not government funding as defined in section 2 of the Public Service Body Rebate (GST/HST) Regulations. ... Therefore, the TWS cannot be considered an amount of money that is paid or payable to the particular person (the eligible employer) by a grantor. ...
GST/HST Interpretation

23 January 2012 GST/HST Interpretation 139980 - GST/HST Interpretation - [Whether a non-resident company is considered to have a] Permanent Establishment [in Canada]

[Addressee] Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 Case Number: 139980 January 23, 2012 Dear [Client]: Subject: GST/HST INTERPRETATION [Whether a non-resident company is considered to have a] Permanent Establishment [in Canada] Thank you for your [...][inquiry] of September 15, 2011, concerning whether a non-resident company [(the Company)] is considered to have a permanent establishment in Canada for purposes of the Excise Tax Act (ETA). ... Based on the information provided and the application of the factors in the policy statement, the Company would not appear to be considered to have a permanent establishment in Canada as defined in subsection 123(1) of the ETA. ...
GST/HST Interpretation

10 June 1996 GST/HST Interpretation 11860-2[6] - Application of the GST to Certain Orthopaedic Braces or Orthotic Devices

It is considered rigid. The supply is zero-rated under section 23. 6. ... The goods are considered to be orthotic devices under section 23.1. 6. ... The are considered to be orthotic devices under section 23.1. XXXXX 1. ...
GST/HST Interpretation

19 February 2003 GST/HST Interpretation 43273 - Visitor Rebate - Breast Implant Material

A breast augmentation procedure is considered a supply of a service. The supply is generally considered a single taxable supply, for the purposes of the ETA, and subject to GST/HST. The breast implant material is considered an input into the taxable service. ... Similarly, the use of botox in a cosmetic procedure would be considered an input into that procedure. ...
GST/HST Interpretation

8 August 1994 GST/HST Interpretation 11870-4-2 - GST New Housing Rebate

Is the individual considered a "builder" as defined in subsection 123(1) of the Act? ... As a result, such individuals will not be considered a builder within the meaning of the Act. ... The individual will then be considered a "builder" of a residential complex. ...
GST/HST Interpretation

17 January 2003 GST/HST Interpretation 6378 - Application of GST/HST to Dietary Supplements

These products are considered to be dietary supplements and are therefore taxable at 7% GST or 15% HST, as applicable. ... This does not include some products commonly considered food that are often imported and sold as concentrated pastes (e.g. anchovy or tomato paste) in tubes. ... Therefore, algae in a liquid format would not be considered a "beverage". ...
GST/HST Interpretation

9 June 2003 GST/HST Interpretation 46149 - Place of Supply of Goods Supplied by Way of Sale

Where a supply of TPP is made by way of sale, the place at which title of the TPP transfers is not the determinative factor in determining where the TPP is considered delivered or made available for purposes of paragraphs 142(1)(a) and 142(2)(a) of the ETA. 2. ... The CCRA's position with respect to where a supply of TPP by way of sale is considered to have been delivered or made available remains as set out in GST/HST Memoranda Series 3.3 Place of Supply. ... In any given case, the place where TPP is delivered or made available may be determined by reference to the place where it is considered to have been delivered under the law of the sale of goods applicable in that case. ...
GST/HST Interpretation

30 November 1998 GST/HST Interpretation HQR0001361 - Operations of a Used Goods Dealer

Is the advance of money by XXXXX considered to be a financial service as defined within section 123(1) of the Act? ... Is the subsequent resale of inventoried property by XXXXX to third parties considered a taxable supply? ... A person who is considered to be a de minimis financial institution is subject to the special input tax credit rules. ...

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