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This view is based upon Policy Number P-015, Treatment of Bare Trusts Under the Excise Tax Act which states that "if independent powers and responsibilities in relation to the management of the property are given to the trustee of the trust instrument, the trustee will be considered to be carrying on a commercial activity in respect of the supplies related to the property... ... As the activities carried out by XXXXX in its capacity as Trustee are viewed as those of the Trust Fund, it is the Trust Fund and not XXXXX which would be considered to be supplying the administrative services to XXXXX Therefore, it is the Trust Fund and not XXXXX which would be required to register for GST, unless XXXXX in its own right is engaged in commercial activities outside of those carried on in respect of the Trust Fund.   ...

. •   any amounts paid by a licenced organization to its bingo association in respect of expenses are "considered pre-paid expenses, and remain gaming revenues... and any surplus remaining after payment of allowable expenses shall be reimbursed to association members on an equitable basis, on a frequency determined by association membership. ... Although a number of other factors have also been considered by the courts in ascertaining whether an agency relationship exists, the ability of an agent to bind the principal is an essential one. ...

The Ministry of Education XXXXX required these "chargebacks" to be reported as revenue and defined as "Transportation Recoveries" as the chargebacks were considered in the funding by the provincial government of that Board's transportation costs. ... In this case, each would be considered to have paid GST on their respective portion of the purchase, notwithstanding that one makes the actual payment. ...

Such renovations and upgrades are not considered, you submit, to be XXXXX since the Funding Parties are obligated under the Multi-Party Agreement to provide the facilities at no cost. 9. ... Notwithstanding your comment that such projects are not considered to be XXXXX, any improvements made to a venue by a lessee (or licensee) such as the Host Society would represent consideration provided to the owner of the venue, assuming that the improvements revert to the owner upon the termination of the lease or licence. ...

Place of supply of MRO work i) General rule Generally, a supply of a service is deemed made in Canada if it is, or is to be, performed in whole or in part in Canada (Subsection 142(1) of the Act) and is deemed made outside Canada if it is, or is to be, performed wholly outside Canada. ii) Drop-shipments Where a supply is made by a registrant to an unregistered non-resident person of a "commercial service" (Per subsection 123(1) of the Act, a "commercial service" in respect of TPP means any service in respect of the TPP other than a service of shipping the TPP supplied by a carrier, and a financial service.) in respect of tangible personal property (TPP), such as MRO work, the GST/HST drop-shipment rules must first be considered as they can affect the registrant's liability to collect tax and the place where the supply is deemed made (Section 179 of the Act). ... An "emergency" is considered to be an unforeseen event or combination of events that calls for immediate action. ...

These conditions are considered in greater detail in the explanation below. ... Other factors that could be considered in determining whether there was an intention to rent, or alternatively to sell, the Complex include: 1. ...

Once it has been determined that the supply is taxable, other factors must be considered to establish the amount of tax that is collectible. ... We have briefly described the factors that must be considered to determine the tax status under the following headings of "Place of Supply- Canada", "Place of Supply- Participating Province", and "Zero-rated Supplies": Place of Supply- Canada When determining if a supply is subject to GST/HST, one must first determine if the supply is deemed to be made inside or outside Canada. ...

Section 9 of the Regulations sets out the formula to determine whether the CI of a pool of gasoline or diesel is considered to be lowered for purposes of subsection 5(2) of the Regulations for a compliance period. ... Subsection 23(1) of the Regulations states that any compliance credit created under subsection 19(1) or section 20 of the Regulations is considered to be a provisional compliance credit (Footnote 11) at the time that it is created. 13. ...

Section 9 of the Regulations sets out the formula to determine whether the CI of a pool of gasoline or diesel is considered to be lowered for purposes of subsection 5(2) of the Regulations for a compliance period. ... Subsection 23(1) of the Regulations states that any compliance credit created under subsection 19(1) or section 20 of the Regulations is considered to be a provisional compliance credit (Footnote 11) at the time that it is created. 13. ...

The interrelationships among the various elements of the transaction, the purpose of an agreement, the needs of the customer, and the economic reality of the agreement are among the factors considered to determine whether an agreement provides for a single supply or multiple supplies. ... As such, if the predominant element of the single supply is determined to be a particular service, then the GST/HST status of the supply as a whole will be considered to be that particular service. ...