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GST/HST Ruling

12 May 1998 GST/HST Ruling HQ0000746 - Application of the GST/HST to the Activities of a University With Respect to the Supply of Cattle

An organization will be considered to be owned by a university if: (a) the university owns all or substantially all (at least ninety percent) of the shares or capital of the organization; or (b) the university holds title to the assets of the organization or controls its disposition, such that in the event of wind-up or liquidation, these assets are vested in the university. ... As cattle is considered to be livestock (Under the Feeds Act and according to ordinary meaning), and is ordinarily raised as food for human consumption, the sale of cattle is zero-rated. If an animal is considered to be livestock that is ordinarily raised or kept for human consumption, it is zero-rated even if it is intended for other purposes (e.g. research) in certain cases. ...
GST/HST Ruling

20 March 2003 GST/HST Ruling 42269 - Eligibility as a Band-empowered Entity

Explanation Based on TIB B-039R, an entity is considered to be owned by a band, a tribal council or a group of bands other than a tribal council if: •   the band, tribal council or group of bands owns all or substantially all (90 per cent) of the shares or holds all or substantially all of the memberships of the entity; or •   the band, tribal council or group of bands holds title to the assets of the entity or controls its disposition, such that in the event of wind up or liquidation, these assets are vested in the band. An entity is considered to be controlled by the band, tribal council or group of bands if: •   the band, tribal council, group of bands or individual members of the band, tribal council or group of bands, appoint or elect a majority of the members of the governing body of the entity (e.g., directors); and •   the entity is required by legislation, by-laws, or an operating agreement, to submit to the band, tribal council or group of bands, its operating budget and where applicable, its capital budget for review and approval. ... " To be considered a BEE, the entity must meet either of the requirements for ownership or control noted above. ...
GST/HST Ruling

7 January 2003 GST/HST Ruling 42430 - Application of GST/HST to [Powdered Drink Mixes]

Rather, these products are represented as being for another purpose and so are not considered to be basic groceries. There are a number of factors that the CCRA considers in determining whether a product would be considered to be a food, beverage or ingredient. ... In fact, P-240 clearly states that, "products would be considered to be food or beverages if they would be consumed by an average consumer when food or beverages are typically consumed, such as at mealtimes or for a snack. ...
GST/HST Ruling

16 August 2022 GST/HST Ruling 225972 - & INTERPRETATION – […][Whether the Product is a zero-rated Basic Grocery item]

It is our position that the Product is considered to be a similar product for the purpose of paragraph 1(m). ... Bars of this nature are not considered to be granola bars, but rather cereal bars or muffin bars. ... For the purposes of this provision, establishments are considered by the CRA to be providers of prepared food and beverages whose sales of taxable food and beverages constitute 90% or more of their sales. ...
GST/HST Ruling

30 March 2023 GST/HST Ruling 237843 - The application of GST/HST to supplies of […][a supplement]

Moreover, to be considered an ingredient, the final product must, in and of itself, be a food or beverage. Thus, a product that is marketed for its beneficial effects and that is added to a food or beverage simply as a way to consume it would not be considered as an ingredient. ... The product is compared to other products that are not considered to be a food, beverage or ingredient. ...
GST/HST Ruling

18 February 2013 GST/HST Ruling 149984 - […] [Carrying on Business in Canada] – Requirement to be Registered

GST/HST Policy Statement P-051R2, Carrying on Business in Canada (P-051R2), sets out factors and principles to be considered in determining whether a non-resident is carrying on business in Canada for GST/HST purposes. ... P-051R2 further states that in general, a non-resident must have a significant presence in Canada to be considered to be carrying on business in Canada, and specifically indicates in this regard that generally, isolated transactions carried on in Canada as part of a business that is carried on by a non-resident person outside Canada may not result in the person being considered to be carrying on business in Canada for GST/HST purposes, given that the factors would usually not be met to a sufficient degree. ... These factors, along with the location of a bank account in Canada, are significant and sufficient for [TourCo] to be considered to be carrying on business in Canada for GST/HST purposes. ...
GST/HST Ruling

5 February 2013 GST/HST Ruling 141852 - Cross–Border Crude Oil Transactions

The crude oil is considered to be sold from [Company A] to [Company B] either before or at the point that it is injected into the pipeline. ... Furthermore, a reduction in consideration is not considered to have occurred if the goods are sold back to the original supplier. To be considered a reduction of consideration, it must be evident that the goods are being returned to the supplier rather than being sold to the supplier. ...
GST/HST Ruling

29 March 2012 GST/HST Ruling 129519 - GST/HST Ruling - Point-of-Sale book rebate on the supply of instructor manuals

The Products are considered to be designed primarily for educational purposes and are not considered to be designed primarily for writing on for the purposes of section 259.1. Therefore, Products A, B and C are considered to be qualifying property for purposes of the Rebate. ...
GST/HST Ruling

10 May 2011 GST/HST Ruling 103495 - [...] [Joint Venture Election]

Therefore, these services are not considered to be acquired by the Municipalities for consumption, use or supply in the course of a commercial activity. ... Where a payment (or a part of it) made by the Municipalities to [Municipality A] pursuant to section [...] of the Agreement is made in respect of the acquisition of capital real property or improvements thereto by [Municipality A] as agent of the Municipalities, the payment (or that part of it) would be considered to be a reimbursement by the Municipalities to [Municipality A]. ... Consequently, where [Municipality A] pays the supplier of such capital real property (or improvements thereto) for acquiring such ownership, the payment by the Municipalities to [Municipality A] would be considered a reimbursement of amounts incurred by [Municipality A] as agent of the Municipalities. ...
GST/HST Ruling

3 March 2011 GST/HST Ruling 108217 - Supplies of Wigs Made to Individuals

Our additional research indicates that some cranial hair prostheses are considered to be of a "medical quality" in that they are designed to fit the shape of a head that has little or no hair and the materials used in the construction are designed not to irritate a sensitive scalp. ... We considered two sections within Part II of Schedule VI that might be relevant to the supply of cranial hair prostheses: sections 25 and 36. ... Our findings indicate that wigs generally are considered to be fashion accessories or costume accessories. ...

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