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If this is the case, it is likely that the elements being provided are contingent on one another and therefore, any one of these items could be considered a single supply in its own right. 3. ... The points in question 3 of scenario 2 have to be considered in answering this question. ...

Interpretations Requested We have been asked to determine: 1. if the operator of the joint venture is engaged in a commercial activity; 2. whether a joint venture election can be made pursuant to subsection 273(1); 3. if the operator acquired the land "on behalf of" the other joint venture participants and can, therefore, claim an input tax credit for the GST paid on the acquisition; 4. whether each of the participants of the joint venture would be considered to be a "builder", pursuant to the definition of builder in subsection 123(1); and 5. the tax status of the supply of each strata-titled unit when the complex is completed. ... Based on the information provided, the operator, in this case, will be considered to be engaged in a commercial activity since the operator will be making supplies of real property (e.g. supplying the undivided interests in the Development in exchange for a divided interest). ...

Answer 2: In circumstances where a partnership-owned passenger vehicle is used personally by a member of the partnership (or an employee of a member of the partnership), the partnership is not entitled to an input tax credit on the acquisition or importation of the passenger vehicle by virtue of subsection 202(2) of the ETA since that use is considered not to be use in the partnership's commercial activity. ... The reimbursement is considered to be a separate supply and tax equal to 7/107 of the amount reimbursed is remitted by the employer in the return for the reporting period in which the reimbursement was received from the employee or shareholder. ...

If GST was collected by the Estate it will be considered to be an amount collected as GST in error that must be remitted. XXXXX will be considered to have paid an amount as tax in error for which a rebate is available under section 261 of the ETA. ...

., an intermediary) will be considered to be government funding to the person receiving the payment under the following conditions: i) the payments were originally received by the intermediary from a grantor; ii) the funds paid by the intermediary to the person must be to assist the person in the pursuit of its objectives or to pay for an exempt supply provided to "other persons"; iii) the funds do not flow through more than two intermediaries to the final recipient (for example, from a grantor to a national organization to a provincial organization and then to a local organization); iv) the intermediary provides a Certificate of Government Funding in a form prescribed by the Minister (form GST-322) certifying to the person that the payment is government funding; v) the funds are recorded in the annual financial statements of the recipient non-profit organization as government funding. ... Similarly, it was not the intention of the legislation that funds provided by an intermediary body (that were received from a grantor) should be considered government funding if the intermediary acquires an exempt supply from the person in return for providing the funds. ...

It is the Department's position that the services provided by XXXXX of arranging for, on behalf of the dealership, customer financing for the purchase of new and used vehicles from the dealership and arranging for, on behalf of the dealership, (which, in turn, is acting on behalf of the insurer) the issuance of optional life and disability insurance policies would be considered to be part of a financial service for GST purposes under paragraph (l) of the definition of "financial service" in subsection 123(1) of the Excise Tax Act (the "Act"). ... The services she provides of arranging for, on behalf of the dealership, customer financing for the purchase of new and used vehicles from the dealership and arranging for, on behalf of the dealership, the issuance of optional disability and life insurance policies would be considered to be part of a financial service for GST purposes under paragraph (l) of the definition of "financial service" in subsection 123(1) of the Act. ...

To be considered an allowance, the following criteria must be met: •   the amount must be limited and predetermined; •   the amount must be paid to enable the recipient to discharge a certain type of expense; •   the amount must be at the complete disposition of the recipient; •   there is no requirement to repay or account for the use of the amount. ... Lastly, because we have not been provided with sufficient information with respect to amounts which are categorized under "travel", we are unable to determine whether these amounts are considered to be a "reimbursement" or an "allowance". ...

However, if XXXXX supplied the charter bus trip and if the other legs of the journey were included in the tour package supplied by XXXXX the departure point of the continuous journey would be considered to be XXXXX departure point. ... Even if it was considered as part of the transportation services provided by XXXXX this service begins in Canada and therefore the origin of the continuous journey would still be in Canada and taxable. ...

Furthermore, the case law does not identify any support for a specific age, neither is there any reference in the Income Tax Act to a chronological age where you are considered aged. ... They decided to abandon the use of 65 years as a criterion for determining when a person is to be considered aged and instead based their determination on the facts of each case. ...

Each modular home, together with the land to which the home is affixed, is considered a "single unit residential complex" as per the definition in subsection 123(1). ... "maintenance fee", etc.) are considered to be part of the consideration for the supply of the real property and therefore, take on the same tax status, in this case that being GST exempt. ...