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With respect to the courses being offered, policy P-229 states: To be considered a vocational school the…instruction in courses offered by an organization must develop or enhance students' occupational skills. ... Therefore we are unable to conclude if the [Dance school] would be considered a vocational school for purposes of the ETA. ... Generally, courses in sport, games or hobbies or other recreational or cultural pursuits, or courses designed for personal interest are not considered to be part of a full time program which provides an individual with the competence to practise or perform a trade or vocation. ...

To be considered a vocational school the instruction in courses offered by an organization must develop or enhance students' occupational skills. ... Therefore we are unable to conclude if [XYZ Dance School] would be considered a vocational school for purposes of the ETA. ... Generally, courses in sport, games or hobbies or other recreational or cultural pursuits, or courses designed for personal interest are not considered to be part of a full time program which provides an individual with the competence to practise or perform a trade or vocation. ...

Subsection 274(3) states that an avoidance transaction means any transaction (a) that, but for this section, would result, directly or indirectly, in a tax benefit, unless the transaction may reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit; or (b) that is part of a series of transactions, which series, but for this section, would result directly or indirectly in a tax benefit, unless the transaction may reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit. ... Subsection 274(4) states that for greater certainty, subsection 274(2) does not apply in respect of a transaction where it may reasonably be considered that the transaction would not result, directly or indirectly, in a misuse of the provisions of Part IX of the ETA or in an abuse having regard to the provisions of this Part (other than this section) read as a whole. ... Under subsection 37(2) in Part 2 of the Regulations, if (a) a transaction, or a series of transactions, involving property is made between two or more persons, all of whom are not dealing with each other at arm's length at the time any of those transactions are made, (b) the transaction, any of the transactions in the series of transactions or the series of transactions would in the absence of this section result directly or indirectly in a tax benefit to one or more of the persons involved in the transaction or series of transactions, and (c) it may not reasonably be considered that the transaction, or the series of transactions, has been undertaken or arranged primarily for bona fide purposes other than to obtain a tax benefit, arising from a harmonization event, for one or more of the persons involved in the transaction or series of transactions, the amount of tax, net tax, input tax credit, rebate or other amount payable by, or refundable to, any of those persons under Part IX of the ETA, or any other amount that is relevant for the purposes of computing that amount, shall be determined as is reasonable in the circumstances in order to deny the tax benefit to any of those persons. ...

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. ... Based on the information provided, since the services performed by Corporation X as part of the Administrative Services assist the Providers and Employers in administering the employee benefit plans, the extended health plans and the dental plans, those Services, when considered as a whole, are predominantly taxable services. ... Those services are therefore not considered supplies of exempt financial services unless subsection 4(3) applies to the services. ...

If multiple supplies are being provided by a person, the possible application of sections 138 and 139 should also 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. ... In these circumstances, the Services performed by an Insurance Broker in consideration of the commission paid on the issuance of a property and casualty insurance policy would generally be considered to be arranging for the supply of the insurance policy and would not be excluded from the definition of financial service by any of paragraphs (n) through (t) of that definition. ...

An "excluded activity" is generally an activity that is normally carried on by an employer for purposes other than for administering a pension plan; accordingly, excluded activities are not considered "pension activities". ... In this case, we confirm that the services supplied by the third party in respect of the employer pension plan deductions would be considered as a "specified resource" for consumption use or supply in a "pension activity", and would generally be subject to the deeming rules of section 172.1. ... Finally, notwithstanding the above classifications, please note that no particular specified resource or employer resource will in all cases be considered as relating to a "pension activity". ...

To be considered a commercial service, there must be a functional relationship between the service and the property. ... Based on the information provided, the XXXXX of the XXXXX with the XXXXX would not be considered to be the supply of a service in respect of the XXXXX. ... " Based on the information provided, XXXXX is considered to have made a supply of the XXXXX to XXXXX. ...

Based on the Product's Nutrition Facts the Product does not meet the requirements, outlined in the Food and Drug Regulations, to be considered either a meal replacement or a nutritional supplement. ... Put differently, products would be considered to be a food or a beverage if they would be consumed by an average consumer when food or beverages are typically consumed, such as at mealtimes or for a snack. ... Where the focus is on the benefits of the product, rather than the form per se, this is an indication that the product would be considered a dietary supplement rather than a food, beverage or ingredient. ...

Where there is an agreement, it seems clear that the children would be considered to be in a commercial activity as they are making a supply of real property. ... However, even in the absence of a "lease, licence or similar arrangement" entered into between the parents and the children, XXXXX believes that the children could still be considered to be in a commercial activity. ... The supply of a remainder interest in the farmland by the parents to their children would, therefore, be considered to be a supply of real property. ...

However, it appears that GST is being charged on any amounts billed which are not considered to be in respect of bus drivers' wages. ... If the ruling by the Board is not sufficient evidence that an employer/employee relationship exists, what other factors should be considered before making a ruling.? ... The excerpt speaks to some of the factors which may be considered in assessing whether a person is an employer and refers to some of the leading jurisprudence in the area. ...