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If the cost of the leasehold improvements are considered to be inputs into the supply of "executing the lease" and therefore eligible for ITCs, would these inputs (leasehold improvements) be considered capital property at the time of being eligible for ITCs? ... If not, would these inputs be considered non-capital property at the time they are eligible for ITCs and therefore subject to section 196.1 when the registrant begins to use the leasehold improvements exclusively in exempt activities? ... The registrant contends that since the act of entering into a lease is considered to be a taxable service, then, under common law, leasehold improvements become the property of the landlord at the time they are made and would, therefore, constitute a supply made by the tenant to the landlord. ...

More specifically, can XXXXX be considered as having paid the Division III tax despite the fact that XXXXX invoiced XXXXX separately for a reimbursement of the GST? ... In general, the person who is considered to have paid tax, whether or not that person is the de facto importer, is the person indicated as the importer of record on the B3 Customs form. ... A copy of the B3 Customs Coding Form will be considered sufficient evidence for purposes of paragraph 169(4)(a) and subparagraph 180(a)(ii) of the Act. ...

Is the purchase of an insurance book considered to be the purchase of a customer list, goodwill or both? ... With respect to the transaction in question, the purchase of the insurance book is considered to be the purchase of a customer list rather than of goodwill. ... " Therefore, the customer list would be considered to be eligible capital property. 3. ...

Casual versus commercial importations If the shipments are being cleared as casual importations, the mail order company cannot be considered the importer. It is the customer in Canada who is considered to be the importer and who is liable to pay the GST at time of importation, whether or not that amount of tax is paid by someone else on their behalf. ... Thus, the sale to the customer is considered to be a supply made in Canada. ...

Pulpwood and logs cannot be considered to have the same primary end-use. ... These actions would be considered further processing. In addition, logs and chips are not similar in general appearance nor do they have the same primary end-use. ... Although the value of this transaction has not been quantified, it is considered to be an even exchange (i.e. the chips and the logs have the same value). ...

In this regard, the key factor to be considered is the substance of the contract for the supply. ... It has already been established that the supply made in scenarios 1, 3 and 4 is considered to be a supply of a service. ... The supply of taxidermy or carving is considered to be a supply of a service in scenarios 1, 3, and 4. ...

For GST/HST purposes, a feedlot is considered to be a confined space (such as a pen, corral or a barn) where livestock are fed a concentrated diet for the purposes of producing a marketable animal. Where the intent of the boarding is for a different purpose than producing a marketable animal, and, where livestock are free to roam on pastureland and graze, the supply is not considered a feedlot operation for GST/HST purposes. 4. ... If the supply is considered a single supply of boarding, (where it is for purposes other than a feedlot operation) the supply is subject to GST/HST calculated on the total charge for the supply. ...

Specifically, to the extent that Co A acts as an agent in making a supply of the IPP on behalf of Co B, then it is Co B, as the principal, who is considered to be making a taxable supply to the recipient of the IPP and Co A, as the agent, who is considered to be making a taxable supply of agent services to Co B. ... We would further add that if Co A collects tax on the supply of IPP it makes on behalf of Co B, it is Co B, as the principal on whose behalf Co A is acting that is considered to have collected that tax. Finally, as set out in draft policy P-182, Determining the Meaning of "Agent" and "Agency", our position is that a person will be considered and treated for GST/HST purposes as an agent based on fact and the principles of law. ...

The operation of the non-gaming activities would be considered elements forming part of that single supply. ... Under the net tax calculation set out in the Regulations, only those activities that are considered gaming are included in the definition of a casino operating service. ... Conclusion Whether the components of a casino operating service are considered to be a single supply or multiple supplies, the amount of tax collected by CCRA remains the same. ...

A supply of IPP may be considered to be made in Canada even if it is not actually used in Canada. ... Subparagraph 2(d)(i) of Part III of Schedule IX to the Act states that a supply of IPP is considered to be made in a province if all or substantially all of the Canadian rights in respect of the IPP can be used only in the province. ... Subparagraph 2(d)(ii) of Part III of Schedule IX to the Act states that a supply of IPP is considered to be made in a province if the place of negotiation for the supply is in the province, and the property can be used otherwise than exclusively outside the province. ...