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However, where the compensation is income from an office for purposes of the Income Tax Act, and is not excluded from the definition of “office” in the ETA, the individual is considered to be performing a duty or act in the course of or in relation to an office or employment and, therefore, GST/HST does not apply to the amount paid. ... The performance of the offices of the attorneyship and the executorship by [Executor A] is not considered to be a taxable supply made in the course of a commercial activity and is, therefore, not subject to GST/HST. ... However, in the absence of direct evidence to support the position that this is the case we […] conclude that [Executor B] performed the executor services in relation to an office and he is not considered to have made a taxable supply in the course of commercial activities. ...

Therefore, a partnership is considered to be a separate person from its partners. ... The definition of financial service speaks of receipt as well as payment to, and so both transactions are considered exempt supplies. ... If the landlord makes a cash payment to the lessee as an inducement to enter into the lease, the lessee is considered to have made a taxable supply to the landlord. ...

However, paragraph 271(b) provides, in part, that the new corporation will be considered to be the same corporation as, and a continuation of, each of the predecessor corporations for prescribed purposes. ... The result is that, where a section 150 election is in place and an amalgamation occurs, the new corporation will be considered to be the same corporation as, and a continuation of, each of the predecessor corporations for purposes of section 150. ... Where an amalgamation of the SLFI or the corporation occurs, the new SLFI or the new corporation will not be considered to be the same corporation as, and a continuation of, each predecessor as referred to in paragraph 271(b), for purposes of subsections 225.2(4) and 225.2(5). ...

Also, whether in a given situation, an address would be considered to be the relevant address on the basis that the address is the address of the agent of a company that is the recipient of the supply. ... Under section 144.1, a supply that is made in Canada is also considered to be made in a particular province if it is determined to be made in the province under the place of supply rules in Schedule IX. ... The relevant address of the recipient does not have to be an address obtained in respect of every supply made to the recipient for it to be considered a relevant address obtained in the ordinary course of business. ...

If is determined that multiple supplies are being provided by a person the possible application of sections 138 and 139 should be considered. ... If the predominant element of the single supply is determined to be a financial service, then the supply as a whole will be considered a financial service. ... While the Person's service may assist the Advisor in providing a financial service of issuing or transferring securities, the service considered as a whole is a referral service. ...

Moreover, in order to be regarded as an ingredient to a food or beverage, the final product, in and of itself, would be considered to be a food or beverage by the average consumer. As with food and beverages, it is also recognized that some products that would be considered to be ingredients by an average consumer have no nutritive value. ... In addition, a product that is marketed for its beneficial effects, and that is added to a food or beverage simply as a means of consuming it, would not be considered by an average consumer as an ingredient simply because it is ingested in this manner. ...

If you determine from the above ITA definitions that your truck is considered to be a motor vehicle, then the capital property rules in the ETA will apply. ... When the motor vehicle is for use primarily in commercial activities, the registrant is considered to use the property exclusively in such activities and may claim a full ITC subject to the conditions in section 169 and the time limitations for claiming an ITC in section 225. ... Regardless of whether a truck is considered to be a motor vehicle or a passenger vehicle, a registrant would not be eligible to claim an ITC for tax paid on the purchase of a truck in 1998 as the four-year limitation period in paragraph 225(4)(b) of the ETA has expired. ...

A non-resident person who has a permanent establishment in Canada is considered to be resident in Canada for GST/HST purposes in respect of the person's activities carried on through that establishment. ... USCo is considered to be making supplies through CanCo, as the business activity that is carried on through CanCo is an essential and significant part of the particular overall business activity of USCo. ... Having a permanent establishment in Canada means that USCo is considered a resident of Canada for GST/HST purposes with respect to activities of USCo carried on through that permanent establishment. ...

Moreover, in order to be regarded as an ingredient to a food or beverage, the final product, in and of itself, would be considered to be a food or beverage by the average consumer. As with food and beverages, it is also recognized that some products that would be considered to be ingredients by an average consumer have no nutritive value. ... In addition, a product that is marketed for its beneficial effects, and that is added to a food or beverage simply as a means of consuming it, would not be considered by an average consumer as an ingredient simply because it is ingested in this manner. ...

For example, where the individual used the property in the course of commercial activities while living, the estate will be considered to have used the property in the course of commercial activities; where the individual had paid tax while living, the estate will be considered to have paid tax; and where the individual had claimed ITCs while living, the estate will be considered to have claimed the ITCs. ... Consequently, where the estate substantially renovates the single unit residential complex of the deceased, section 267 does not operate to deem the estate to be the deceased individual so that the deceased individual could be considered as the "particular individual" who substantially renovated the complex for purposes of paragraph 256(2)(a). ...