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Whether services performed by the Investor are considered to be a single supply or multiple supplies under the [Program] Agreement is a question of fact. ... If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 should be considered. ... If not, then the Investor’s services would be considered the provision of multiple supplies. ...

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. Conversely, if the printed book supply is incidental to the supply of the other item, then no part of the supply will be considered to be that of a printed book. ... In the event that a printed book and another item are considered to be two supplies, rather than a single supply of a new item, and neither supply is considered to be incidental to the other, then it will be necessary to allocate the consideration between the part attributable to the book and the part attributable to the other item. ...

We have reviewed the Question and Answer data base and, in our view, we have not taken the position that student councils are always to be considered as separate from their related school authorities. ... Other issues may be relevant in individual cases, and each situation should be considered on a factual basis. Thus, the answer clearly indicates that in some instances, a student council may be considered to be part of a school authority, rather than being considered a separate person for GST purposes. ...

A supply of a vehicle will be considered to have met that criteria even where a particular recipient transports the vehicle to the point of export by driving the vehicle himself from the supplier's premises to that point. ... In your particular case, painting a used vehicle is considered a transformation or alteration which changes the physical appearance of the property. ... However, repairs necessary as a result of testing would be considered further processing. ...

Interpretation Given A corporation engaged in the business of acquiring and developing commercial real estate for the purposes of leasing or selling the developed property will generally be considered to be engaged in commercial activities for GST purposes. ... Section 141.01 of the Act sets out rules for determining the extent to which an input will be considered to have been acquired for consumption or use in commercial activities. ... In general, to the extent that an input is acquired for consumption or use in making taxable supplies for consideration, the input will be considered to have been acquired for consumption or use in commercial activities. ...

All of the relevant facts and circumstances surrounding the transactions must be taken into account in determining where delivery is considered to take place. ... However, where the supplier of the TPP in such a case, acts as the "importer of record" and pays Division III tax, the supplier would not be considered to be the importer of the TPP for the purpose of subsection 169(1) of the Act and would not be entitled to an ITC in respect of Division III tax. In such a situation, it is the Canadian recipient that would be considered the importer of the TPP for purposes of claiming an ITC. ...

Accordingly, these receipts will also be considered exempt supplies under section 1, Part VII of Schedule V to the ETA. ... Accordingly, the supply is considered an exempt supply under the ETA. ... Lastly, whether a trust fund is considered a de minimus "financial institution" is based on the formula provided under paragraph 149(1)(b) of the ETA. ...

If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 should 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. ... Accordingly, the ISO’s service and the Representative’s service are both considered the provision of a single supply. ...

In these situations, the supply of the broadcast or communication service will be considered to be a supply of an advertising service. ... Where there are no restrictions regarding the place of use of the IPP, generally, it is considered that the IPP may be used in Canada. ... As such, the memberships supplied to XXXXX are considered to be made in Canada as the memberships may be used in Canada. ...

It is our view that a particular entity will be considered and treated for GST/HST purposes as an active or bare trust based on fact and principles of law. ... Where an active trust exists, the trustee would be considered as carrying on the commercial activity related to the trust property, and any supply made by the trustee, as trustee of the trust property, would be considered an activity of the trust. ... Conversely, the beneficiaries of a bare trust would generally be considered to be engaged in commercial activities iiFootnote 2 relating to the trust property. ...