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Whether a particular unit has the same permanent residential characteristics as a house such that it is considered to be a "residential unit", is affixed to the land, and is used as a place of residence for individuals is determined on a case-by-case basis taking into consideration the facts and circumstances of the particular case. Based on the facts referred to above, the trailer is affixed to the land in a manner conducive to long-term residential use and is sufficiently modified to add the necessary characteristics, including permanency, such that the trailer is considered to be a similar premises for purposes of the definition of "residential unit". ... As such, the trailer is considered to be a residential unit that is affixed to the land. ...

The CRA's position with respect to where a supply of TPP by way of sale is considered to have been delivered or made available is set out in paragraphs 7 to 11 of GST/HST Memoranda Series 3.3, Place of Supply. ... In any given case, the place where TPP is delivered or made available may be determined by reference to the place where it is considered to have been delivered under the law of the sale of goods applicable in that case. ... The factors that will be considered in determining whether a non-resident person is carrying on business in Canada for GST/HST purposes in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made; •   the place from which transactions are solicited; •   the location of an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ...

However, in the absence of such terms, the place where the tangible personal property is delivered or made available may be determined by reference to the place where the tangible personal property is considered to have been delivered under the law of the sale of goods applicable in that case. ... As such, where this takes place in Canada, the supply of the books by the Printer would be considered to be made in Canada and subject to tax at 7% unless zero-rated (taxed at 0%) as an export. ... Where it is determined that the supply by the Printer is made in Canada and not zero-rated, the supply of the books by the Printer is considered to be made in a participating province where the Printer ships the books to a destination in a participating province or transfers possession of the books to a common carrier that the Printer has retained on behalf of the recipient to ship the property to such a destination. ...

Rather, these facilities are long-term care facilities that provide residential care and these facilities do not satisfy the criteria, as explained below, to be considered public hospitals under the ETA. ... However, in order for a facility to be considered a "public hospital" for GST/HST purposes, the facility must meet the following four criteria: (a) The facility must be recognized as a public hospital by the government of the province in which it is located. ... When a facility no longer satisfies all four of the requisite criteria, the facility is no longer considered to be a public hospital for purposes of the ETA. ...

An entity may be considered to be organized solely for non-profit purposes if its aims and activities are directed toward the general improvement of conditions within one or more areas of business. ... Such an entity is normally considered to be an extension of the members' sales organizations and will be considered to be carrying on a normal commercial operation. ...

A band-empowered entity is considered to be situated on a reserve when the entity maintains a presence on a reserve. ... Any resulting GST/HST payable in respect of the property or service is, therefore, considered to be payable by the partnership and not by the member. For a partnership to be entitled to claim an ITC to recover all or part of the GST/HST payable in respect of property or a service that is considered to be purchased by the partnership, the partnership must be a registrant during the reporting period in which the GST/HST becomes payable or is paid without having become payable, and the other conditions for claiming an ITC must be met. ...

The Creator’s supply of a license or right to use its content would generally be considered as a supply of IPP. ... In other words, a supply of IPP could be considered to be made in Canada even if it is not actually used in Canada. ... As such, the content supplied to [the Company] could be considered to be made in Canada as the content may be used in Canada. ...

Furthermore, a gift card must have the characteristics of a gift certificate as described in GST/HST Policy Statement P-202, Gift Certificates, to be considered a gift certificate within section 181.2; in other words, for a gift card to be considered a gift certificate, the gift card: a) must have a value or be for a particular supply of property or services; b) be redeemable for the purchase of property or services; c) consideration must have been given; and d) have no intrinsic value. ... If XXXXX is not a registrant, the recipient is liable to self-remit for the applicable GST/HST on the value of consideration of the XXXXX Card at the time it is redeemed since the recipient has acquired the property for use in Canada but XXXXX is considered to make its supply outside Canada. ... Therefore, XXXXX Cards are considered gift certificates within section 181.2: The XXXXX Cards have value; they can be redeemed for the purchase of any property (in this case, a selection of music); consideration has been given for the XXXXX Cards; and the XXXXX Cards have no intrinsic value. ...

If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 must also 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. ... The facts and circumstances of each transaction would have to be considered on their own merits. ...

([FinanceCo]), there is a question as to whether [Organizations C] may be considered as arranging for a single supply of exempt "financial services" to be provided by [FinanceCo]. ... Based on the information provided, [Organizations C] activities when considered as a whole are predominantly in respect of the promotion and marketing of the Loyalty Program. ... Also, [Organizations C] are not in the business of providing supplies of financial services or considered a financial intermediary as described under subparagraph 149(1)(a)(iii). ...