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You are questioning when subsection [1]93(1) would ever apply and why subsection 193(2) must be considered when section 211 does not make reference to that subsection. ...

Again, we note that the amount would not have been subject to tax under the other possible tax treatments considered. ...

However, a service of "fostering", when provided by individuals, is generally not considered to be a commercial activity and, consequently, fees paid to foster parents are not subject to GST/HST. ...

It is our position that a person will be considered and treated for GST/HST purposes as an agent based on fact and principles of law. ...

When the working interest is considered a business or part of a business, the election under subsection 167(1) may be available. ...

In any case, whether the boarding services were supplied separately, and were considered incidental, or as part of a single supply, section 4 of Part V of Schedule VI to the Act would apply to zero-rate the consideration relating to the boarding services. ...

For property to be considered partnership property, while title to that property is registered in the name of the individual, there must be evidence indicating that the property is partnership property. ...

In this case, the subject payment is considered as part of a lease payment or additional rent. ...

Training provided by the volunteer agency is not considered to be a fire protection service. ...

Interpretation Requested You have presented the following facts: •   A US resident corporation (USCO) is considered to be carrying on business in Canada effective January 1, 1991, and, as such, was required to be registered for GST purposed as of that date. •   USCO was not registered for, nor did it collect or remit any GST on taxable supplies made in Canada for the period January 1, 1991 to June 30, 1999. •   USCO made a voluntary disclosure in respect of the failures set out above, and was duly assessed upon audit. •   Under the Canada Customs and Revenue Agency's (CCRA's) own policy, USCO is not subject to any penalty or interest on its failure to register for or collect and remit tax at the correct time, but it is required to collect and remit tax due. •   In order to pay the assessment levied on audit, USCO raised GST-only invoices to recover the tax originally due dated October 1999. ...