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Where the software is supplied electronically (downloaded as a digitized product) it is considered to be a supply of intangible personal property (IPP). ... Hardware sales This is considered to be a supply of tangible personal property. 6. ... Account coordination (arranging third-party subcontracts) This is considered a supply of a service. ...

For example, if the portion of a Web site design service that is performed in Canada is performed entirely in XXXXX, the supply of the Web site design service is considered to be made in XXXXX. ... XXXXX's supply of Web site hosting and its supply of hosting the replicated Web site are considered to be computer-related services. ... As the XXXXX software is considered to be intellectual property for GST/HST purposes, it is zero-rated under this section when provided by XXXXX to a non-registered non-resident. ...

Is an upfront grant paid by a government (i.e. federal, provincial or municipal) to a builder to help defray the cost of construction considered to be: "government funding for the purpose of making residential units in the complex available to individuals referred to in (2)(b)"? ... It will be a question of fact whether an upfront grant paid by a government (i.e. federal, provincial or municipal) to a builder to help defray the cost of construction is considered to be "government funding for the purpose of making residential units in the complex available to individuals referred to in (2)(b)". Generally, where the grantor agrees to defray construction related expenses incurred by a builder in respect of a subsidized residential complex, the amount received by the builder will be considered to be government funding under subsection 191.1(1). ...

To be considered a therapeutic health care service, the service must relate to care or treatment of an individual's injury, illness or disability. ... Appendix 2 to this memorandum contains a summary of the dictionary definitions that were considered, including those noted above. ... In this situation, the service rendered by the [Care assistant] may be considered a therapeutic health care service for purposes of subparagraph (a)(iii) of the definition of "facility supply". ...

We have carefully considered your submissions. However, our position remains that a trust does not qualify as a band-empowered entity under TIB B-039. ... As such, a trust is considered a separate person from its trustees and beneficiaries. ...

Specifically, would the amount representing the GST be considered an amount "for which it can reasonably be regarded the person has obtained or is entitled to obtain a rebate, refund or remission under any other section of this Act or under any other Act of Parliament" as described in subparagraph 259(1)(b)(ii) of the definition of "non-creditable tax charged"? Interpretation Given It is the CRA's position that an amount representing a percentage of GST/HST paid that is included in a grant pursuant to a funding agreement is not considered to be an amount in subparagraph 259(1)(b)(ii) that is "... a rebate, refund or remission under any other section of this Act or under any other Act of Parliament. ...

Ruling Requested You would like to know whether The Plan can reasonably be considered a MEPP and therefore is eligible for the rebate provided for under section 261.01. ... Subsection 261.01(1) clearly states that in order to be considered a MEPP for purposes of the rebate, a pension plan must meet the definition of "multi-employer plan" in subsection 8500(1) of ITR. ...

The agreements further provide that tender, general provisions, specifications, special provisions and plans attached to the agreement are considered to be part of the latter. 4. ... Questions You asked if the haulage of the gravel may be considered as a separate supply or is part of the supply of constructing the road/stockpiles. ...

A seasonal use of property in which the owner retains control and access to the whole of the premises is generally considered a supply made by way of licence. Accordingly a right to moor a boat in a marina would normally be considered a licence of real property which is taxable, except for agreements provided by public service bodies entered into before September 15, 1992, in which the period of the licence must be less than one month to be taxable (or for agreements of at least one month entered into before September 15, 1992, the body elected to charge GST). ...

It is our opinion that the late penalties and vaccination charges can be considered part of the consideration for the supply of the zero-rated hogs. ... On the other hand the charge made for "employee services" is not considered to be part of the consideration for the supply of the hogs. ...