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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 the terms of its own written trust agreement. ...

A band-empowered entity is considered to be situated on a reserve when the entity maintains a presence on a reserve. ...

In addition, section 1.2 of Part II of Schedule V must also be considered. ...

As well, we understand that the value of the transaction(s), the frequency of the transaction(s), the nature of the supply and the status of the recipient may be factors that will be considered […] in establishing whether the requirements set out in TIB B-039 are met. […]. ...

On the other hand, where an employer resource is acquired by the employer for consumption or use in the course of pension activities in respect of a pension plan but not for supply to a pension entity, the deeming provisions of subsection 172.1(7) must be considered. ...

INTERPRETATION REQUESTED You would like to know whether the PST and GST added to the amount that was considered as still owing to the Manufacturer under the first lease was done so correctly. ...

Note that if an employer resource is acquired by the employer for consumption or use in pension activities but not for supply to a pension entity, the deeming provisions of subsection 172.1(7) must be considered. ...

In such circumstances, the employer would generally be considered to be making a supply of the relevant property or services to the plan trust, and sections 221, 225 and 228 would generally require a registrant employer to collect and remit GST/HST calculated on the consideration for the supply. ...

As set out in GST/HST Memoranda Series 4.5.3 (4.5.3 Exports- Services and Intellectual Property), for purposes of section 23 of Part V of Schedule VI XXXXX, an advisory or consulting service is not considered to include any work that might be undertaken or performed as a result of the plans or recommendations accepted by the client or the advice provided by the client. ...

Accordingly, certain branch office expenses incurred outside Canada in respect of a Canadian activity that are allocated to a Canadian head office such as salaries, rent and entertainment expenses may be considered to be qualifying consideration after the application of the formula A-B in proposed subsection 217.1(1). ...