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You will note that, in general, a non-resident person must have a significant presence in Canada to be considered to be carrying on business in Canada. ... Although the telephone is mobile and free to go anywhere, the mobile telephone will be considered to be "ordinarily located" at the permanent address of the purchaser subscriber. ...

Prior to April 1, 1998 all paramedical services are considered to be tax exempt supplies. ... Consequently, the supply of "paramedical" services by a registered nurse to clients is a taxable supply as this service is not considered to be a nursing service. ...

ABM moves or relocations are considered to be new Installs. The installation of ABMs (inital or pursuant to moves) is a supply of IT services and is taxable. 7. ... These fees may be considered necessary to cover the company's administrative costs in relation to the taxable supply of installation and as such would be taxable. 8. ...

As set out in policy P-182, our position is that a person will be considered and treated for GST/HST purposes as an agent based on fact and the principles of law. ... As previously indicated, if the establishment is in fact acting as an agent of the crafter, the application of section 177 of the ETA should be considered. ...

. •   While the XXXXX approached the Town about the possibility of construction of the Centre, the Town Council and the Mayor agreed that a Centre was needed but they said the Town was not in the position to come up with the money; however, the Town said it would support the XXXXX and to your knowledge, no other alternatives were considered. •   It is the understanding of the XXXXX that it owns the improvements to the land until such time as the Centre is completed for occupancy and use. 12. ... For example, we have no evidence of a lease agreement being in effect between the Town and the XXXXX such that the XXXXX may be considered to have a leasehold interest in the property. ...

The Canada Customs and Revenue Agency (the CCRA) maintains the position that where two or more taxable supplies, other than zero-rated supplies, are made, the requirements of subsection 223(1) of the ETA are considered to be met where the supplier indicates the aggregate consideration for those supplies and the aggregate amount of tax that is payable in respect of those supplies. ... Therefore, where an LDC who is a registrant, causes or facilitates the making of the supply by the retailer under an agreement with the retailer, the LDC would be considered to be the intermediary of the retailer. ...

Whether upgrades/extras may be included in the NHR calculation under the provisions of section 254 will depend upon whether they can be considered to form part of the supply of the qualifying unit. In general, amounts in respect of extras may be included in the total consideration paid for NHR purposes so long as: •   the extras can be considered fixtures or appurtenances reasonably necessary for the use and enjoyment of the unit as a place of residence within the subsection 123(1) definition of a 'residential complex'; and •   the amounts for these extras are paid or payable to the builder before transfer of ownership of the qualifying unit occurs. ...

As the supply of Internet access is not deemed to be made in Canada under the provisions of paragraph 142.1(2)(a) of the Act, it will be considered to be made outside Canada. ... Each of the multiple supplies must be considered separately for purposes of determining whether the supply is made in Canada, zero-rated, or made in a non-participating or a participating province. ...

It is the CCRA's position that a person will be considered and treated for GST/HST purposes as an agent based on fact and principles of law. ... Municipal Determination In your letter, you refer to certain entities as having been determined to be municipalities and therefore considered "para-municipal organizations" as defined in section 1, Part VI, Schedule V to the ETA. ...

Under such circumstances, a particular person would be considered to be a builder of a residential complex when that particular person constructs a residential complex or engages another person to carry on for the particular person the construction of a residential complex. ... If the supply is exempt under section 2 of Part II of Schedule V or section 2 or 3 of Part IV of the same Schedule for example, the supply may not be considered to be exempt under section 6 of Part I. ...