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Although once installed, the equipment is considered to form part of the real property, the contract for the supply and installation cannot be considered the construction, renovation or alteration of, or repair to, real property. ... In this particular case, the elements (i.e. the work carried out at each location) would not be considered inputs. ... The annual Program Monitoring Services fee would, however, be considered a separate supply of a service. ...

The website construction, maintenance and hosting services are considered to be made in Canada pursuant to paragraph 142(1)(g) of the ETA if they are performed in whole or in part in Canada. ... Where 90% or more of the service is performed in a participating province, it will be considered to be made in the participating province and subject to HST at 15%. ... As such, web hosting is considered a computer-related service for the purposes of the Place of Supply (GST/HST) Regulations. ...

Where there are no restrictions regarding the place of use of the IPP, generally, it is considered that the IPP may be used in Canada. For example, where the agreement for the supply does not specifically restrict the client's access to the program to the location of the school, or otherwise, the supply will be considered to be made in Canada. However, if the agreement for the supply states that the client may only access the program from computers located in a specified school and that school is located outside Canada, the supply is considered to be made outside Canada. ...

In order to be an operator of a JV for purposes of the election, a registrant must first be considered a participant in the JV. ... Where the person does not engage staff to perform any of the operator’s duties, it is doubtful that the person would be considered to have the managerial or operational control of the JV. ... In the absence of a signed agreement between the Co-Owners and the Manager, we cannot state that the Manager would be considered to have managerial or operational control of the JV. ...

However, Metered Street Parking considered for the purposes of this application ruling is limited to on street parking controlled by meters. 12. ... If Metered Street Parking is considered as the supply under consideration, section 10 of Part VI of Schedule V to the ETA will not apply as less than "substantially all" Metered Street Parking is supplied for no consideration. ... To determine whether "substantially all" of a recurring supply like parking is supplied for no consideration similar properties of parking are considered. ...

Moreover, in order to be regarded as an ingredient to a food or beverage, the final product, in and of itself, must be considered to be a food or beverage by the average consumer. ... Among other factors, the CRA will consider labelling, packaging and marketing to determine whether a product would be considered a "food", "beverage", or "ingredient". ... Product E is considered to be food. As previously mentioned, supplies of food are zero-rated unless one of the exclusions in paragraphs 1(a) through 1(r) of Part III of Schedule VI to the ETA applies. ...

Where the predominant element of the supply is an exempt service, the supply would then be considered an exempt supply. On the other hand, where the predominant element is a taxable service, the supply would then be considered a taxable supply. ... Where it is determined that section 138 does not apply and at least one of the multiple supplies provided together for a single consideration is a supply of a financial service, then the application of section 139 should be considered. ...

You also feel that XXXXX [a]ctivities in Canada can be considered regular or continuous based on a letter received from Headquarters dated December 31, 1991 and that these activities in Canada are engaged in twice a year, year after year. ... While this is a valid concern, the criteria to be considered as set out in the policy paper entitled Carrying on Business in Canada and GST memorandum 200-1-1 will, in most cases, be the determining factors as to whether the non-resident has a significant presence in Canada and can be considered to be carrying on business in Canada. ... The main theme of the criteria, as set out, is to determine if a non-resident has significant presence in Canada so as to be considered to be carrying on business in Canada. ...

Since the truck was used primarily for transporting goods or equipment in the taxation year in which it was acquired, the truck is considered to be a motor vehicle and not a passenger vehicle. ... The reason is that, although the truck is used for carrying passengers, for GST purposes the truck is never considered to be a "passenger vehicle" (as defined under the ITA) after the taxation year in which it was acquired. ... More specifically, since the truck was considered, in your examples, not to be an "automobile" for income tax purposes, we also agree with your statement that the special ITC rules for passenger vehicles would not apply for GST purposes. ...

Whether a person will be considered an agent of another person is a question of fact. ... Customs brokers are generally considered agents for purposes of section 5 of Part V of Schedule VI to the ETA. ... Or, would it be considered incidental to the exportation of the goods? ...