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Interpretation Given Based on the information provided, the following interpretation is provided: The supply of designing a web site or updating the information on and/or design of the web site is considered to be a supply of a service for GST/HST purposes where the supplier does not retain any property rights to the site or the updates. ...

., "A definitive ruling in regards to ITC allocations can only be made on a case by case basis, as the facts of any particular case must be considered."-    ...

" Thus since the university is the person liable under an agreement to pay the consideration in this situation, the supply by R is considered to be "made to" the university.) the university by virtue of the agreement between R and the university. ...

In most securitizations there is an amount set out in the sale agreement that dictates how much is being paid for the purchase of the mortgages as well as an amount which can be considered to be an amount in respect of servicing. ...

Paragraph 1(m) of Part III of Schedule VI to the ETA excludes from zero-rating supplies of: cakes, muffins, pies, pastries, tarts, cookies, doughnuts, brownies, croissants with sweetened filling or coating, or similar products where (i) they are prepackaged for sale to consumers in quantities of less than six items each of which is a single serving, or (ii) they are not prepackaged for sale to consumers and are sold as single servings in quantities of less than six, but not including bread products, such as bagels, English muffins, croissants or bread rolls, without sweetened filling or coating; It is the CCRA's position that the product is considered to be a "similar product" for the purposes of paragraph 1(m) of Part III of Schedule VI to the ETA. ...

However, paragraph 271(b) provides that the new corporation will be considered to be the same corporation as, and a continuation of, each of the predecessor corporations for prescribed purposes. ...

Interpretation Given It has long been the CCRA's position that where a person is contracted to provide a delivered item or delivered information for that matter, the delivery is considered an input of the supply and the GST/HST is applicable. ...

While the applicability of an election pursuant to subsection 167(1) is a question of fact in each case, the supply by a partnership of an undivided interest in the partnership property to one of the partners would generally not be considered to be a supply of a business or part of a business because it can't operate on its own and as a result, the election under subsection 167(1) would not be available. ...

As further indicated in the Notice, goods temporarily imported and then exported, which have been subject to full GST at the time of importation, are considered to be tax paid for purposes of any subsequent importation. ...

In most circumstances, under subsection 177(1.2) of the Excise Tax Act (ETA), when a registrant auctioneer auctions tangible personal property (such as livestock) on behalf of an owner, the auctioneer is not considered to have made a supply to the owner of services relating to the supply of the property. ...