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Hallway connection Where [the Company] constructs the two duplexes and connects the two duplexes by a hallway, it is not clear that this would be considered to be the construction of a multiple unit residential complex containing four residential units. For purposes of the PBRH rebate, the development would have to be considered to be a single building rather than two separate buildings in order for the condition under subsection 4(2) of the Regulations, that the multiple unit residential complex include at least four residential units, be satisfied. ... For purposes of the GST/HST NRRP rebate, a multiple unit residential complex situated on a single legal land description that contains not more than two residential units where each unit contains private kitchen facilities, a private bath and a private living area is considered to be a single unit residential complex. ...

The webbing does not have to be manufactured into nets to be considered webbing for the purposes of this provision. ...

As indicated in the March 10, 2010 interpretation, flight passes are generally considered supplies of intangible personal property for GST/HST purposes. ... Where an exchange is initiated by an air carrier (e.g., customers are moved from a cancelled flight to a different flight), the air carrier is considered to be fulfilling its obligation to provide the passenger transportation service to the customer. ... If so, there is an additional requirement for the travel agency under the transitional rules, since the travel agency will be considered the first supplier of the tour packages during the transitional period for the HST in Ontario and British Columbia. ...

Where XXXXX, the US Entities or the Club enforces their security interests, the enforcement is considered to be a seizure or repossession of the resort points for purposes of section 183 of the Excise Tax Act ("ETA"). ... In this case, the requirements of subsection 183(1) are met and the "reacquisition" is considered to be a seizure for ETA purposes. ... The supply of resort points is taxed on the portion that is considered to be supplied in Canada. ...

INTERPRETATION REQUESTED You would like to know whether the supply of goods by Trading Co. to customers in Canada, under the circumstances you have described, would be considered a supply made outside Canada by virtue of section 144. ... Various provisions in the ETA reflect the fact that the supply is considered to be made when the agreement is entered into. ... A supply by way of sale of goods that are delivered or made available in Canada to the recipient is generally considered to be made in Canada by virtue of subsection 142(1). ...

INTERPRETATION REQUESTED Where diesel or gasoline is used in a propulsion engine, but not all of the energy that the fuel and the engine generate is used for propulsion, is all of the fuel still considered to be “fuel for use in a propulsion engine”? ... The vehicles mentioned are not likely to meet the weight requirement for qualifying motor vehicles (they would be over 3,000 kilograms) and therefore the fuel used in this capacity would not be considered specified property and services under paragraph 28(1)(b). However, should any of these vehicles weigh under 3,000 kilograms and meet the other requirements to be a qualifying motor vehicle, the motive fuel used therein, other than diesel fuel, would be considered specified property and subject to recapture. ...

In addition, since US2 is a qualifying subsidiary of Hold Co. and US4 is a qualifying subsidiary of US2, then US4 is considered to be a qualifying subsidiary of Hold Co. ... Since US4 is a qualifying subsidiary of Hold Co. and C1 is a qualifying subsidiary of US4, then C1 is considered to be a qualifying subsidiary of Hold Co. ... Since C1 is a qualifying subsidiary of Hold Co. and C3 is a qualifying subsidiary of C1, then C3 is considered to be a qualifying subsidiary of Hold Co. ...

Whether the Corporation would be considered a supplier of [Product A] for GST/HST purposes would be based on the legal substance and commercial reality of the transaction evidenced by the intentions of the parties. ... If this is the case, the Corporation as the supplier of [Product A] would be considered to have made taxable supplies of [Product A] and therefore would have an obligation to charge, collect and remit GST/HST in respect of those supplies. ... Moreover, the Corporation’s Service would not be considered the “arranging for” a financial service under paragraph (l) of the definition of financial service in subsection 123(1) since the exceptions to the definition under paragraphs (r.3), a credit management service, and (r.4), a service that is preparatory to the provision of a financial service, would apply to the Service. ...

The Form GST111 is considered to be part of what is prescribed as the return that is required in section 238. ... As indicated above, no specific form is indicated in subsection 238(4) as a return, but rather the Minister has the right to authorize any form to be considered the prescribed form for this return, and to specify what information is to be included on such form as prescribed information. ... As the Form GST111 is not considered to be a separate return, we do not consider it to be an information return. #2- Whether section 284 and/or section 326 apply to a late filing or failure to file the Form GST111: Section 284 states: Every person who fails to provide any information or document when and as required under this Part or under a regulation made under this Part is, except where the Minister waives the penalty, liable to a penalty of $100 for every failure unless, in the case of information required in respect of another person, a reasonable effort was made by the person to obtain the information. ...

[INTERPRETATION GIVEN] We have considered the new ITC allocation method proposed by […][the financial institution], as explained by […], and as outlined in the documentation you provided, for claiming its excluded, direct and non-attributable inputs. ... Note that an input that might be considered an indirect input for cost allocation purposes (for example, certain overhead expenses) is a direct input for purposes of section 141.02 if the business input is not an excluded or exclusive input and can be attributed in whole or in part to the making of a particular supply or supplies. 2. ... The following highlights some of the specific requirements of [the specified criteria, rules, terms and conditions] which should be considered in [the financial institution]’s proposed method: The method should be meaningful: To be meaningful, the method should accurately reflect the extent to which the particular business inputs were acquired or consumed and used for the purpose of making taxable supplies for consideration and for purposes other than making taxable supplies for consideration. […][The specified criteria, rules, terms and conditions require] that a specified method for an excluded input or a direct attribution method for a direct input employ tracking to allocate an input if possible before using causal allocation, and use causal allocation where possible before using an input-based allocation or an output-based allocation. ...