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A "proprietorship" is generally considered to mean a business that is owned by a person who has either the legal right and exclusive title or dominion or who has ownership of the business. ... If a business is a sole proprietorship, (i.e., a business that is owned and controlled by one individual) then it will not meet the definition of a non-profit organization as the "person" will be considered to be an individual. ... We consider therefore, that a proprietorship established and operated by a number of individuals would not necessarily be excluded from the definition of a non-profit organization on the basis that the "person" in this situation is considered to be an individual. ...

Some goods are excluded from being considered basic groceries, among those goods are some dietary supplements. Pills, Tablets, Capsules and Similar Formats Certain classes of dietary supplements are not considered to be basic groceries. ... Beverages All carbonated beverages, including those which may be considered dietary supplements, are subject to GST at 7%. ...

Where all of the above conditions are met, the supply of the property would be considered to be a supply made otherwise than in the course of a commercial activity. ... In addition, although a simple foreclosure order may involve a judgment with respect to an amount owing under the mortgage, such an action is not considered to be a money judgment which is a condition of subsection 183(3). ... Assuming that there was and the rest of the conditions of 183(3) were met, the supply of the property would be considered to be made otherwise than in the course of a commercial activity. ...

The development costs of the land are considered to be part of the land value for purposes of subsection 254.1(2) of the Act. 2. ... However, those improvements involving the development of the land itself cannot be severed from the land and should be considered to be part of the land. Accordingly, that part of the consideration for the supply of the buildings which should be allocated to the development costs of the land is considered to be consideration for the supply of the land. ...

As grants are not considered to be supplies for GST purposes, expenses incurred by XXXXX in relation to the provision of grants only are not viewed as being for use in commercial activity and they do not give rise to ITCs. ... As the supply of a financial service (other than a supply included in Part IX of Schedule VI to the ETA) is an exempt supply, such loans and advances made by XXXXX would be considered to have been made otherwise than in the course of commercial activities. 3. ... As the supply of a financial service (other than a supply included in Part IX of Schedule VI to the ETA) is an exempt supply, such payments made by XXXXX would be considered to have been made otherwise than in the course of commercial activities. 4. ...

Accordingly, if the supply is considered to be made in a participating province it will be subject to HST. ... The general rule pursuant to section 2 of Part V of Schedule IX to the ETA is that the supply of a service is considered made in a province if all or substantially all of the service is performed in that province. If that is not the case, then the supply of the service is considered made in the province in which the place of negotiation of the supply is located, provided all or substantially all of the service is not performed outside of that province. ...

Accordingly, if the supply is considered to be made in a participating province it will be subject to HST. ... The general rule pursuant to section 2 of Part V of Schedule IX to the ETA is that the supply of a service is considered made in a province if all or substantially all of the service is performed in that province. If that is not the case, then the supply of the service is considered made in the province in which the place of negotiation of the supply is located, provided all or substantially all of the service is not performed outside of that province. ...

Therefore, if these types of accounts are not considered to be segregated funds (i.e. a trust), then part of the pension plan would not be considered to be "in trust". ... ANALYSIS Since the Investment Management Fee is charged to and paid for by the segregated fund, it is the segregated fund that is considered to be the recipient of the supply. ... In order to be considered a registered pension plan pursuant to the Income Tax Act, the pension plan must be funded through specific funding media. ...

Interpretation Given The term advertising is not defined in the Act, however, the Department has provided an explanation as to what is generally considered to be an advertising service in Memoranda Series section 4.5.3 Exports- Services and Intellectual Property. ... In these situations, the supply of the broadcast or communication service will be considered to be a supply of an advertising service. The provision of a Spot on a web-site is considered to be a service of communicating a message. ...

Is the supply of access to the internet from a XXXXX located outside Canada to a person who is also located outside Canada where the bill-to address is in Canada considered to be an export of a service? ... The supply of access to the internet through a XXXXX will be considered to be "making available... telecommunications facilities" and therefore, the provision of a telecommunication service. ... If the telecommunication service is not deemed to be made in Canada pursuant to subsection 142.1(2) of the Act it would be considered to be made outside Canada. ...