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GST/HST Interpretation

9 April 2025 GST/HST Interpretation 247209 - Mining activities in respect of cryptoassets after February 4, 2022 via mining pools

However, where a person earns compensation that is determined based on an estimate of potential mining payments and the amounts are not adjusted to the actual mining payments, the person may not be considered to share in the mining payments. ... Where a CSP contributes computing resources to a mining pool operated by an Operator, a CSP is considered to pool its property or services for the performance of mining activities with other members of the mining group. ... If a CSP’s payments based on the “X” value received for its June 1st contributions are subsequently adjusted to reflect the June 2nd payout based on the “Y” value, this would be considered an adjustment to the payment and the initial payment received by the CSP on June 1st is considered an advanced payment whereas the adjustment indicates a payment method that is based on the actual block subsidy and/or transaction fees received by the mining pool. ...
GST/HST Interpretation

24 March 2015 GST/HST Interpretation 141407 - Master trust

In our view, a trust is considered to be governed by a registered pension plan if the trust holds all the property of a pension plan and is governed by its own written terms (i.e., trust agreement). ...
GST/HST Interpretation

21 April 2015 GST/HST Interpretation 167787 - Eligibility for ITCs in respect of pension expenses

Under that subsection, the trust is considered to be a separate person from the insurer, and the insurer is deemed to be the trustee. ...
GST/HST Interpretation

27 March 2015 GST/HST Interpretation 168698 - Beneficiary pension plans in a master trust arrangement

Note, however, that a master trust cannot normally be considered as a pension entity as master trusts are not generally governed by a registered pension plan.  ...
GST/HST Interpretation

8 June 2017 GST/HST Interpretation 184056 - PROPOSED LAW/REGULATION - Repeal of the rebate for tour package-related accommodations

Based on the information provided in your example, the umbrella agreement between […] and a UK agent would not be considered to be a supply of a tour package or accommodations. ...
GST/HST Interpretation

10 January 2018 GST/HST Interpretation 163984 - Eligibility for corporation to claim full ITCs

. […] Generally an allocation method that allocates the input to particular supplies in the most direct manner, such as tracking the use of inputs, is an unbiased and objective method that would be considered to be fair and reasonable. ...
GST/HST Interpretation

24 March 2014 GST/HST Interpretation 133894 - Request for ministerial exception

Having considered the information above and consulted with interested parties such as Finance Canada that use the information collected, it has been determined that the Minister will not exempt […] [ABC] from the requirement under subsection 273.2(3) of the ETA to provide information related to the prescribed amounts of tax for the purpose of paragraph (a) of Element A and F in subsection 225.2(2) of the ETA and as described in paragraph 40(a) of the Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations on the Annual Information Return. ...
GST/HST Interpretation

22 July 2014 GST/HST Interpretation 158585 - Tax Status of [a] [Fruit Snack]

It is our understanding the [Variety 1] product and the [Variety 3] product do not contain multiple fruits and are therefore not considered salads. ...
GST/HST Interpretation

4 February 2014 GST/HST Interpretation 159039 - Eligibility of a group of corporations to file a section 156 election

Each member of the group of corporations that would be the electing entities (C1, C2, C3 and C4) must be closely related under section 128 in order to be considered to be a member of the same qualifying group under paragraph (a) above. ...
GST/HST Interpretation

17 November 2008 GST/HST Interpretation 106266 - Paragraph 149(1)(c) of the Excise Tax Act

More precisely, you would like clarification concerning the following situations: Whether the interest revenues generated by cash balances from a business bank account required for the day-to-day operation of a business are considered to be with respect to the "making of an advance" or the "lending of money"? ...

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