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Having said this, the central issue in the case at hand becomes whether the employee's use of the passenger vehicle provided by the registrant is considered to be commercial activity of the registrant. In other words, is the use of the passenger vehicle by the registrant considered to be 80% (i.e., less than exclusively) in commercial activity or is it used exclusively (i.e., 80% + 20%) in commercial activity? ... If this was the case, the employee's personal use of a passenger vehicle would only be considered to be use in commercial activities where that use was less than 50%. ...

Since XXXXX office would not be considered to be an agency PE, their supplies can be considered made to a non-resident. ... Therefore, an insurance agent's or broker's services can be considered to be supplied to a non-resident and in this way the supplier is not forced to make an allocation which it is not in a position to make accurately. ... If it can be established that XXXXX exceeded the $30,000 threshold prior to October 1992 XXXXX would be considered a registrant and would have been required to be registered but for the Policy P-035. ...

IT-447 reads: "... a trust is generally considered to reside where the trustee, executor, administrator, heir or other legal representative who manages the trust or controls the trust assets resides...." With respect to self-directed RRSPs and RRIFs, the management and control of the trust rests with the trustee and, given that the trustee is resident in Canada, the trust is also considered to be resident in Canada. ... The trust is considered to be resident in the location where the trustee resides. ...

When the restaurant sells the gift card, is it a transaction that is considered a taxable supply made to the retailer? ... When the retailer sells the gift card to the public, is the transaction considered a taxable supply? ... When given as consideration for a supply at the restaurant, the gift card is considered to be money. ...

Single ingredient salads which consist of one ingredient and a dressing or seasoning are also considered to be salads. ... Packages of ingredients must include a dressing or seasoning to be considered a salad. Where there is no dressing or seasonings applied to the other ingredients or supplied with or made available with the other ingredients, the supply is not considered a salad. ...

Our XXXXX District Office has advised you that the above packaging is not considered to be a usual covering or usual container for the purposes of section 137 of the Excise Tax Act (ETA) and that since the value of the packaging is considered significant in relation to the value of the entire supply, the packaging is not considered to be incidental for the purposes of section 138 of the ETA. You were advised that the supply is considered a single supply taxable at 7%. ... Your packaging materials are considered to be usual for purposes of section 137. ...

It is your view that the arrangements, whereby the XXXXX and the XXXXX provide rights to XXXXX to use real property, should be considered a supply by way of lease and not by way of licence. ... Further, the improvements constructed on the property by XXXXX would be considered capital property thereby entitling XXXXX to full input tax credits in respect of such construction costs in accordance with section 209 of the Excise Tax Act. ... The excess amount would be considered an amount incurred by XXXXX on its own behalf that does not reasonably relate to the lease of the property. ...

Whether services performed by the ISO are considered to be a single supply or multiple supplies under each agreement is a question of fact. ... If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 should be considered. ... If not, then the ISO’s services would be considered the provision of multiple supplies. ...

Situation 3 For GST/HST purposes, a transfer of possession of property to a person is considered to be a sale only if the person takes possession under an agreement to transfer ownership of the property. ... The current tenure holder will be considered to have possession of the land under an agreement to transfer ownership of the land only at the time that possession is held under an agreement of purchase and sale. ... Situation 4 Land of up to a half hectare that is subjacent and immediately contiguous to a residential building is generally considered to form part of the residential complex as it is considered to be reasonably necessary for the use and enjoyment of the building as a place of residence. ...

4. is the combination of the two allowances considered unreasonable and therefore no input tax credits are allowed on any portion of the amounts? ... Is the combination of the two allowances considered unreasonable and therefore no input tax credits are allowed on any portion of the amounts? ... Again, these payments are considered to be two separate allowances. The fixed motor vehicle allowances of $65.00 and XXXXX per day are considered not to be reasonable allowances for income tax purposes since they are not based solely on kilometres driven by the employee. ...