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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 license. Accordingly, an agreement or right to moor a boat would normally be considered a licence 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. ...

If the shipments are being cleared at Customs 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 to Customs on their behalf. ...

In order for a facility in Canada to be considered a college, it must be established and operated pursuant to the relevant provincial legislation governing the establishment of "colleges". Similarly, in order for a facility to be considered a technical institute, it must be registered or licensed as an educational institution pursuant to relevant provincial legislation. ...

In order for a facility in Canada to be considered a college, it must be established and operated pursuant to the relevant provincial legislation governing the establishment of "colleges". Similarly, in order for a facility to be considered a technical institute, it must be registered or licensed as an educational institution pursuant to relevant provincial legislation. ...

Issue: When will athletes participating in a curling bonspiel be considered "professional participants" pursuant to section 11 of Part VI of Schedule V of the ETA? ... In determining whether an individual is a "professional participant", the following criteria may be considered: 1) Is there a regulatory body which governs the sport? ...

Issue: When will athletes participating in a XXXXX be considered "professional participants" pursuant to section 11 of Part VI of Schedule V of the ETA? ... In determining whether an individual is a "professional participant", the following criteria may be considered: 1) Is there a regulatory body which governs the sport? ...

Information Requested 1) Is the Liquor and Gaming Commission considered to be a "board, commission or other body established by a government" for the purposes of section 20 of Part VI of Schedule V to the ETA? 2) Were the Liquor Board and the Liquor Licensing Commission each considered to be a "board, commission or other body established by a government" for the purposes of section 20 of Part VI of Schedule V to the ETA? ...

As stated in the previous paragraph, the supply of a study made in this manner would be considered to be the supply of a service. ... Prior to January 1, 1991 (during the FST regime), the supply of the needs/feasibility study by XXXXX and by XXXXX, would also have been considered to be the supply of a service. ...

The supply of an easement, including an easement in gross, can be considered to be either (a) a supply of an arrangement similar to a lease or licence, or (b) a supply of real property by way of sale. Where an easement is granted in perpetuity, and where the only amount ascertained is a single consideration, as in the case at issue, the supply would be considered to be a supply of real property by way of sale. 2. ...

Department's Position: In their letter dated March 20, 1996, the Business and General Division of the Income Tax Rulings and Interpretations Directorate indicated to you that a motorhome is not considered to be an "automobile" within its definition under subsection 248(1) of the Income Tax Act, but rather is a "motor vehicle" under that Act included in class 10(a) of Schedule II to the Regulations. For GST purposes, since the motorhome is considered to be a "motor vehicle" under the Income Tax Act, the capital personal property rules provided under subsection 199(2) of the ETA will apply to determine whether a GST registrant is entitled to claim an ITC on the GST payable on the acquisition of the motorhome. ...