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Although the term "advertising" is not defined in the Act, the Canada Customs and Revenue Agency (CCRA) 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. Although ForCo is not involved in the creation or design of the advertising message, its provision of advertising space in magazines is considered to be a service of communicating the message and therefore a supply of an advertising service. ...

A band-empowered entity is considered to be situated on reserve when the entity maintains a presence on reserve. An entity is considered to be owned by a band, a tribal council or a group of bands other than a tribal council if: •   The band, tribal council or group of bands owns all or substantially all (90 per cent) of the shares or holds all or substantially all of the memberships of the entity; or •   The band, tribal council or group of bands holds title to the assets of the entity or controls its disposition, such that in the event of wind up or liquidation, these assets are vested in the band. ... However, where services are performed both on and off-reserve for a single consideration, and all or substantially all the services are for real property on-reserve, the services for real property off-reserve would be considered part of the supply of the services for real property on-reserve. ...

In these situations, the supply of the broadcast or communication service will be considered to be a supply of an advertising service. ... Based on the information provided, this supply is considered to be a service directly related to the communication of a message. As such, the supply XXXXX is considered to be a supply of an advertising service for purposes of the ETA. ...

In these circumstances the developer would generally be considered to be transferring real property (e.g. dedicated land in the subdivision or development area) in fulfilment of its statutory obligations under provincial legislation and not in return for something that the municipality has supplied. ... In the present case, the developer would be considered for GST/HST purposes to have made a supply by way of sale of the subject property for consideration of XXXXX provided the developer was required to transfer the subject property pursuant to condition imposed by the municipality under XXXXX. In effect, the value of the subject property in excess of XXXXX would be considered for GST/HST purposes to have been transferred to the municipality for nil consideration. ...

Unedited CRA Tags ETA 231; ETA 232; GST/HST Technical Information Bulletin B-042R, Refund, Adjustment or Credit of GST; GST/HST Policy Statement P-084R, Forgiven Debts Considered Bad Debts Please note that the following document, although correct at the time of issue, may not represent the current position of the Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Is the elimination of the reserve by the registered distributor considered to be a bad debt written-off by the registered retailer, pursuant to subsection 231(1) of the ETA? ... Is the elimination of the reserve by the distributor considered to be a "debt forgiven" and does GST/HST Policy Statement P-084R FORGIVEN DEBTS CONSIDERED BAD DEBTS apply? ...

Any top-up value added to the gift card would generally be considered the issuance or sale of a gift certificate for consideration and when redeemed for a supply of property or services shall be deemed to be money as described in section 181.2. Gift cards issued in circumstances when an item is returned without a receipt would generally be considered to be issued for consideration; the value of the returned item being the consideration pursuant to paragraph 153(1)(b). Consequently, a gift card issued in this circumstance would generally be considered a gift certificate for purposes of section 181.2. ...

XXXXX was generally told that the cemetery plots at issue are considered by the XXXXX to be licences because they were not registered on title. ... Accordingly, the supply of an easement otherwise than by way of sale, may be considered a "similar arrangement" to a lease or licence. ... Consequently, such supplies would normally be considered to be by way of lease, licence or similar arrangement. ...

Interpretation Requested Is the building and the land considered to be a "residential complex" as defined for GST purposes under subsection 123(1) of the Act? Interpretation Given Upon reviewing all submitted information, it is our view that the building and the land is considered to be a "residential complex" for GST purposes as defined under subsection 123(1) of the Act. ...

It is also the Department's position that XXXXX is not considered cosmetic surgery for the purposes of section 5 and hence supplies of XXXXX will always be GST exempt. ... Please note that suppliers of GST exempt services are not considered to be engaged in a commercial activity for GST purposes and are not required to be registered for purposes of the tax nor are they entitled to claim input tax credits (ITCs). ...

When XXXXX considered to be making a single supply of a repair service. The materials (e.g., parts) supplied in conjunction with the repair service are not considered to be a separate supply but, rather, one of the elements of the repair service. ...