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Registered supplier of short-term accommodation Under the new digital economy provisions and more specifically pursuant to subsection 211.13(3), where an accommodation platform operator (footnote 3), registered for GST/HST under the simplified regime (footnote 4), facilitates the making of supplies of short-term accommodation (footnote 5) located in Canada through its accommodation platform (footnote 6), on behalf of non-registered suppliers (i.e. hosts), and where the recipients (i.e. guests) of short-term accommodation did not provide evidence satisfactory to the Minister that they are registered under the regular GST/HST regime, the accommodation platform operator is considered to be the supplier of the short-term accommodation. ... You also indicated that before proceeding to do so, you considered awaiting further potential information within the letter to be received from GST/HST Rulings Directorate. 3 Under subsection 211.1(1), an “Accommodation Platform Operator” is defined as a person (other than the supplier of the short-term accommodation) that controls or sets the essential elements of the transaction between a supplier of short-term accommodation and the recipient, or if no such person exists, it would be a person that is involved, directly or through arrangements with third parties, in collecting, receiving or charging the consideration for the supply of short-term accommodation and transmitting that consideration to said supplier. 4 [the Company] is registered under the simplified regime. ...

If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 must also be considered. ... If the predominant element of the single supply is determined to be a financial service, then the supply as a whole will be considered a financial service. ... Accordingly, the supply would generally be considered a taxable supply. ...

The Regulations broaden the conditions under which corporations can be considered to be closely related under section 128 and include instances where the beneficial ownership of the shares arises in respect of the employment of a person or where the shares are held in trust as specified in the Regulations. ... Under paragraph 3(b) of the Regulations, a particular corporation and another corporation would be considered to be closely related for the purposes of paragraph 128(1)(b) if qualifying voting control of the other corporation is held by, and 90% or more of the total value and number of all the specified shares of the other corporation is owned by, one of the following: (i) the particular corporation, (ii) a corporation that is closely related to the particular corporation under paragraph 128(1)(a), (iii) a corporation that is a prescribed corporation in relation to the particular corporation for having met all the conditions described above under paragraph 3(a) of the Regulations, or (iv) any combination of the corporations referred to in subparagraphs (i) to (iii). ... Finally, where two corporations are closely related to the same corporation under the provisions of subsection 128(1), they are considered closely related to each other under subsection 128(2). ...

In considering these factors, the following principles must be considered: * no vacation/transient purpose; * indicators of permanency; * appreciable period of time; * intention; and * purpose of stay. ... Although the principle described in paragraph 16(e) of GST/HST Memorandum 19.2 suggests that an abode occupied by an individual temporarily for work purposes may be considered a person’s place of residence, this principle is not considered in isolation of all other factors. ... In that example, the stay is one year and thus is not considered transient in nature. ...

The Statement indicates that the deposits received equal XXXXX, the first mortgage will be equal to XXXXX and the sum of XXXXX shall be considered the balance due upon closing. ... This sum is to be considered the monthly occupancy fee and takes into account mortgage interest, estimated monthly taxes and monthly common expenses. ... (It should be noted that the following is based on the assumption that the XXXXX are not considered to be "builders" for GST purposes as defined in subsection 123(1) of the Act. ...

Answer: During the course of construction of a residential complex, the NPO would be considered the "builder" of the residential complex as defined for GST purposes in subsection 123(1) of the Act. ... As the supply being provided to the occupant is considered to be a supply of a residential complex, or a unit in a residential complex, by way of lease, licence or similar arrangement, where the conditions under section 6 of Part I of Schedule V to the Act are satisfied, the GST is not applicable to the supply to the occupant. ... For your information, pursuant to subsection 168(9) of the Act, a deposit is not "...considered consideration paid for the supply unless and until the supplier applies the deposit as consideration for the supply". ...

In the event that an amount is credited from the vehicle dealership to XXXXX this is not considered to be a trade-in. ... Where the lessee receives a cash advance from the dealer against the value of the trade-in, the advance is considered a financial arrangement. ... Under the second rule, where the property is a specified motor vehicle, it is considered to be leased in the province in which it must be registered under provincial motor vehicle legislation. ...

For example, if it is normal business practice of the dealer to merely assist in filling out forms then passing them on to the provider of the financial service, this would not be considered arranging for the supply of a financial service. ... A referral service is not considered to be an arranging for service. GST/HST Technical Interpretation Bulletin B-105, Changes to the Definition of Financial Service, provides a number of examples to aid in determining whether a supply of services may be “arranging for” a financial service. ... Where a Dealer is actively involved in the loan application process and effects the Lender’s supply of a financial service, the Dealer may be considered to be “arranging for” a financial service under paragraph (l). ...

Is a leasehold strata lot considered a "residential condominium unit" for GST purposes as defined in subsection 123(1) of the Act? ... The supply shall be considered taxable for GST purposes provided none of the exempting provisions outlined under Part I of Schedule V to the Act are applicable. 2. A leasehold strata lot considered a "residential condominium unit" for GST purposes as defined in subsection 123(1) of the Act. 3. ...

Response We have consulted with the Income Tax Rulings Directorate as to whether an employee expense report would be considered to be a record and whether the expense report along with other supporting documentation is sufficient to support a deduction under the ITA. ... For GST purposes, Policy Statement P-075 " Allowances and Reimbursements " states that a reimbursement is considered to be a payment by an employer to an employee to repay the employee for amounts spent by the employee on the employer's business. ... If this is not the case, then the amount will not be considered to be a reimbursement and, therefore, section 175 of the ETA will not apply to deem the Company to have received a supply of the property or service or to have paid tax in respect of the supply. ...