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XXXXX persons belonging to the Club are considered "lifetime members" and are offered free memberships to the Club. 3. ... If no, the contributions will not be consideration for a supply since there is no activity involved that can be considered to be a supply. ... Since there is no activity present that can be considered to be a supply by the Club, that is, lifetime members do not receive any property, services, or rights or privileges beyond those that occur as a result of their already existing membership, the amounts contributed are not regarded as consideration for a supply (in other words, those rights and privileges conferred to lifetime members are conferred by reason of their membership). ...

Ruling Given Based on the facts set out above, we rule that: One litre plastic containers of XXXXX Grapefruit Sections, XXXXX Pineapple Sections, XXXXX Mango Sections and XXXXX Orange Sections are considered to be supplies of food for human consumption and their supplies are taxable at 0% (zero-rated) pursuant to section 1 of Part III of Schedule VI to the Excise Tax Act (the Act). ... Analysis A fruit salad is considered to be comprised of whole fruit, fruit portions or fruit pieces of two or more types of fruit with or without dressing. A product that is only one fruit is not considered a salad. Therefore, supplies of sections of one type of fruit, sold in plastic containers, are zero rated. ...

In our April 29, 1998 letter, we stated that the supply of each is considered to be a supply of tangible personal property and is excluded from the general exemption by paragraph 2(e) of Part VI of Schedule V to the Excise Tax Act (the "Act"). ... Each of the supplies identified in your letter is considered to be a "supply of information". We are currently reviewing the issue of whether a "supply of information" is considered to be property or a service. ...

Although the contract for referral services involves a monthly billing, each particular referral service is considered to be a separate supply. ... Pursuant to paragraph 2(a) of Part V of Schedule IX to the ETA the supply of each referral will be considered to be made in the province where all or substantially all of the Canadian element of the supply is performed. ... Each supply will therefore be considered to be made in the province where the branch office that made the referral is located. ...

You have asked for our opinion on whether the compensation received by the players is considered to be in excess of the "reasonable amount" described under section 11 of Part VI of Schedule V, with the consequence that this exempting provision would not apply. ... You would also like to know if there is any limit to the dollar amount that would be considered "remuneration" under section 11. ... " Rather than focusing on a particular dollar amount, it is our policy that to be considered "reasonable compensation" for purposes of section 11, the amount should not significantly exceed the costs incurred by the individual related to (i.e., "incidental to") his/her participation in the event. ...

Therefore, a non-resident person considered to be carrying on business for income tax purposes is not necessarily considered to be carrying on business for purposes of the GST. Equally, where it is determined that a non-resident person is carrying on business in Canada for GST purposes, this, in itself, in no way establishes that the non-resident would be considered to be carrying on business in Canada for purposes of the ITA. ...

7 June 2000 GST/HST Interpretation 31018- Warranty Exchange Program Unedited CRA Tags ETA Sch VII, 5 File number: 114678-1June 7, 2000Final 31018 MEMORANDUM FOR: XXXXX Subject: Warranty Exchange Program XXXXX This is in response to your e-mail message dated March 28, 2000, requesting an interpretation as to whether remanufactured XXXXX imported in a warranty exchange program are considered to be a non-taxable importation pursuant to section 5 of Schedule VII to the Excise Tax Act ("the Act"). ... XXXXX, has made a submission to your Directorate, on behalf of XXXXX, rebutting the CCRA's argument that the XXXXX exchange program is not considered to be replacement parts supplied under warranty. ... In order to be considered a non taxable importation, the goods must be supplied under warranty. ...

Issue You have asked if this Casino Grant can be considered "government funding" for purposes of the PSB rebate. ... Notwithstanding the fact that the Council might declare on their financial statements that the grant would be a casino grant, if the contribution is awarded to the Council under the XXXXX program, the contribution is considered "government funding" for the purposes of the PSB rebate. However, if the Council declares Casinos Revenues proceeds from such social occasion casinos, the proceeds would not be considered "government funding" for the purposes of the PSB rebate but consideration for the supply of the right to participate in a game of chance. ...

Interpretation Given As you know, subsection 142(1) of the Excise Tax Act (the Act) provides that a supply by way of sale of tangible personal property is considered to be made in Canada if the property is, or is to be, delivered or made available in Canada to the recipient of the supply. The determination of where goods are considered delivered or made available is based on the applicable sale of goods legislation and all relevant facts and circumstances. ... As noted in your letter, where the goods are consequently considered supplied in Canada, the non-resident registrant is required to collect Division II tax applicable to the value of the consideration for the supply of the goods. ...

It is stated in Policy Statement P-068 " Definition of Time Periods Created by Election/Revocation of Election to Change Fiscal Years " that, for administrative purposes, the time period on which a fiscal year begins and the date on which a fiscal year elected under the provisions of section 244 of the Act begins will be considered to be a fiscal year. ... This "short" period will be considered to be a fiscal year under the provisions of Policy Statement P-068. ... Given our policy that the "short" period that may be created when an election to change the fiscal year is made is considered to be a fiscal year and that all references in the description of element D in the net tax calculation in subsection 17(1) of the Regulations are to net specified supplies for reporting periods in a fiscal year, it is our opinion that the registrant is eligible for the 1% reduction in the Quick Method remittance rate in that "short" period. ...