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XXXXX is considered a "container operator" which, as defined in the Canada Border Services Agency (CBSA) Memorandum D3-7-1, means, "a person or a company who is a lessor of cargo containers classified under tariff item No. 9801.10.00, for use in international service. ... However, for purposes of section 144, the containers in this case are considered to have been delivered or made available to the recipient after their release. ... The containers in this case are considered to have been imported temporarily when they physically enter Canada and are considered to have been released at that time. ...

If the supply of the other item is incidental to the supply of the printed book, then the entire product will be considered to be a printed book. ... Clip-ons, sun-clips and flip ups are considered specially designed accessories for zero-rated prescription eyewear. ... These parts are considered generic since they can also be incorporated into non-prescription eyewear. ...

B-039R states that an entity will be "considered" to be owned by bands when bands hold all or substantially all of the memberships of an entity. ... Consequently, as a membership interest in an entity is comprised of certain membership rights, it is necessary to examine those rights to establish whether the members may be considered as owners. ... Where this condition is met, as in the case of XXXXX, an entity will be considered to be owned by bands. ...

If the deemed sale is not exempt, the individual is considered to have collected tax on the deemed sale calculated on the fair market value of the farmland at the time of the appropriation. ... Where an individual's GST/HST registration is cancelled, the change-in-use rules found under paragraph 207(1)(a), as discussed above, would have to be considered to determine whether the individual is considered to have collected any tax. ... If the sale is exempt, an individual would not be considered to have collected tax on the fair market value of the farmland under subsection 190(2), nor would a GST/HST registrant individual be considered to have collected tax under subsection 207(1). ...

We also understand that you do not have an agreement at this time for us to review to confirm whether a particular supply provided may be considered a financial service. Interpretation Requested Are third party collection services provided by a person at risk, or a person closely related to a person at risk, considered supplies of financial services? ... In order for a supply to be considered to be a financial service it must first be a supply included in paragraphs (a) to (m) of the definition of "financial service" in subsection 123(1). ...

Whether the supply of the gift certificate to another person is considered a supply by Company B or the corporation depends on the circumstances-i.e. whether or not there is an agency arrangement. Agency (supply considered made by Company B) Where the corporation is an agent at law of Company B (i.e. the principal), the supply of the gift certificate to another person would be considered to be made by Company B and not by the corporation (i.e. the agent). ... Consignment arrangement (supply considered made by the corporation) Where the arrangement is one of consignment, the corporation would be considered to have made the re-supply of the gift certificate to another person (and Company B would be considered to have made a supply to the corporation immediately before); and, as in Scenario 1, each supply would be deemed not to be a supply. ...

The aforementioned factors are not individually conclusive in their own right and must be considered as a whole. As well, the factors listed are by no means the only ones that may be considered and other factors may be relevant depending on the circumstances. ... Based on the facts, however, entitlement to a rebate must be considered under section 256. ...

The bagels are considered as unsweetened baked goods, the muffins are considered as sweetened baked goods. ... The supply of a package that contains less than six baked products, such as a package that contains three bagels and two muffins, would be considered a supply taxable at 7% or 15% as applicable pursuant to paragraphs 1(m) or 1(q) of Part III of Schedule VI to the ETA. ... Also, the supply will fail the test of the postamble of paragraph 1(m) as the package cannot be considered as a whole to be unsweetened bread products. ...

However, where a portion of that land is used in commercial activities, such portion is usually not considered to be reasonably necessary for the use and enjoyment of the building as a residence. ... Regardless of the foregoing, where any portion of the land is used for commercial activities, such a portion is usually not considered to be reasonably necessary for the use and enjoyment of the building as a residence. ... All relevant criteria should be considered in making a determination. ...

Interpretation Given A person must first be considered a participant in a particular joint venture in order to be designated as its operator. ... As a result, such a corporation would not be considered as a participant and thus, an operator, of the joint venture for purposes of the section 273 election. ... Each case will be looked at on a case by case basis to determine whether the duties vested in a particular nominee corporation or a trust referred to as a bare trust are sufficient to be considered managerial or operational control. ...