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GST/HST Interpretation
23 February 1999 GST/HST Interpretation HQR0001572 - GST on Capital Building Construction
To assist you in determining whether a particular cost item would be considered to be an "improvement", we should advise that subsection 123(1) of the Act defines improvements to capital property to be property or services acquired or imported for use in improving the capital property to the extent that the consideration for the property or services is included in determining the adjusted case base of the capital property for the purposes of the Income Tax Act (or would be so included if the person were a taxpayer under the Income Tax Act). An item that would ordinarily be considered to be personal property would generally be considered to be an improvement to capital real property only if it becomes a fixture to the real property. ...
GST/HST Interpretation
23 October 2000 GST/HST Interpretation 24883 - GST/HST Status of the Supply of an Internet Auction Service
Whether the bid is considered acceptable depends on whether the bid price exceeds the vendor's pre-authorized minimum acceptable price. ... CANCO is considered by the Canada Customs and Revenue Agency (CCRA) to be supplying a service of arranging for, procuring or soliciting orders for supplies by or to its purchaser and vendor clients. The annual and monthly posting fees and sales commissions charged by CANCO to the vendor are considered by the CCRA to be consideration for the supply of a service of arranging for, procuring or soliciting orders for supplies made by the vendor. ...
GST/HST Interpretation
23 May 2000 GST/HST Interpretation 26857 - Supply of Computer Games Electronically Through the Internet
Considering that the software is not customized for any particular purchaser and is supplied and delivered by electronic means through the Internet, the supply will be considered by the Canada Customs and Revenue Agency (CCRA) to be the supply of IPP. ... Subparagraph 2(d)(i) of Part III of Schedule IX to the Act states that a supply of IPP is considered to be made in a province if all or substantially all of the Canadian rights in respect of the IPP can be used only in the province. ... Subparagraph 2(d)(ii) of Part III of Schedule IX to the Act states that a supply of IPP will be considered to be made in a province if the place of negotiation of the supply is in the province, and the property can be used otherwise than exclusively outside the province. ...
GST/HST Interpretation
18 April 2000 GST/HST Interpretation 25699 - Ruling Request Regarding the Supply of Software Through the Internet from a Server Located in the by a Canadian Resident Registrant
Considering that the security software is not customized for any particular purchaser and is supplied and delivered by electronic means through the Internet, the supply will be considered by the Canada Customs and Revenue Agency (CCRA) to be the supply of IPP. ... Subparagraph 2(d)(i) of Part III of Schedule IX to the Act states that a supply of IPP is considered to be made in a province if all or substantially all of the Canadian rights in respect of the IPP can be used only in the province. ... Subparagraph 2(d)(ii) of Part III of Schedule IX to the Act states that a supply of IPP will be considered to be made in a province if the place of negotiation of the supply is in the province, and the property can be used otherwise than exclusively outside the province. ...
GST/HST Interpretation
31 March 2000 GST/HST Interpretation 7964/HQR0001570 - GST On A Land Lot Purchased And Subsequently Exchanged For Another Land Lot
Consequently, the subsequent transfer of ownership of Lot 1 from the Purchasers to the Developer is considered as another sale of Lot 1 for GST purposes under subsection 123(1). ... Supply of Lot 2 from the Developer to the Purchasers The transfer of ownership of Lot 2 from the Developer to the Purchasers would be considered a "sale" for GST purposes under the definition of sale in subsection 123(1). ... As the sale of Lot 2 by the Developer to the Purchasers does not fall within any of the exempting provisions in Part I of Schedule V, the sale of Lot 2 would be considered a taxable supply. ...
GST/HST Interpretation
21 November 2002 GST/HST Interpretation 30957 - Application of GST/HST to Fees for Access to Mainframe Computer and Consulting Services
Subparagraph 2(d)(i) of Part III of Schedule IX states that a supply of IPP is considered to be made in a province if all or substantially all of the Canadian rights in respect of the IPP may be used only in the province. ... Subparagraph 2(d)(ii) of Part III of Schedule IX to the ETA states that a supply of IPP is considered to be made in a province if the place of negotiation of the supply is in the province, and the property may be used otherwise than exclusively outside the province. ... In either case, the supply of IPP is considered to be made in the participating province with the greatest proportion of the Canadian rights that may only be used in the participating provinces. ...
GST/HST Interpretation
10 October 2003 GST/HST Interpretation 43285 - Tax Status of the Service of Training Apprenticeship Students
For periods prior to January 1, 1997, the College would have been considered a charity for purposes of the ETA. • The XXXXX has entered into an agreement with the College to purchase apprenticeship training courses for delivery to specified third parties (apprentices) according to training standards established by the XXXXX. • XXXXX • XXXXX. • XXXXX § XXXXX § XXXXX § XXXXX. • XXXXX. • The College has filed an election under section 6 of Part III of Schedule V to the ETA to deem the supply of Apprenticeship courses to be taxable for GST/HST purposes. • The courses provided by the College under the Apprenticeship program do not have equivalency for credit courses. • There are situations where a student may be granted exemption for a credit course in a degree or diploma program, but this is evaluated on a case-by-case basis. ... Generally, an individual course is considered by the Canada Customs and Revenue Agency (the CCRA) to meet the "attest to the competence" criterion if the course is offered as a credit in a full-time program offered by the same institution on a pass/fail basis. Alternatively, where the course is not part of a full-time program, it is considered to attest to the competence of individuals to practise or perform a trade or vocation if it is offered on a pass/fail basis. ...
GST/HST Interpretation
27 January 2003 GST/HST Interpretation 35795 - Supply of Web Site Related Services
Interpretation Given Based on the information provided, the supplies of Web site hosting, Web site design and the registering of domain names are considered by the Canada Customs and Revenue Agency (CCRA) to be supplies of services for GST/HST purposes. ... Whether a person is considered and treated for GST/HST purposes as an agent is based on fact and the principles of law. ... A supply of Web site hosting is such a supply as it is considered to be a supply of a "computer-related service". ...
GST/HST Interpretation
23 January 2013 GST/HST Interpretation 132321 - Ballet Lessons
GST/HST Policy P-229, Definition of "Vocational School" in Section 1 of Part III of Schedule V to the Excise Tax Act, explains how to determine if an organization is a "vocational school" within the meaning of the ETA: The above definition sets out three principle criteria that an organization must meet to be considered a vocational school: (a) the organization must be established primarily to provide correspondence courses or instruction in courses, that develop or enhance students' occupational skills; (b) the organization must be operated primarily to provide correspondence courses, or instruction in courses that develop or enhance students' occupational skills; (c) the correspondence courses or instruction in courses must develop or enhance students' occupational skills. ... 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. ... 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. ...
GST/HST Interpretation
15 February 2022 GST/HST Interpretation 233932 - Tax status of COVID-19 testing services
However, BCCNM’s Professional Standards make it clear that clinical practice, education, administration and research are all considered part of the practice of registered nursing.” ... Exempt supplies are not considered to be made in the course of a commercial activity. ...