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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. ... Under the Contract, the Administrator is considered to be providing a service to the Employer for which it receives an administration fee that is excluded from the definition of financial service since the Administrator is not a person at risk. ...

In determining if an intermediary's service is included in paragraph (l), all the facts surrounding the transaction, including the following factors, must be considered: • the degree of direct involvement and effort of the person in the provision of a financial service referred to in any of paragraphs (a) to (i); • the time expended by the intermediary in the provision of a financial service referred to in any of paragraphs (a) to (i); • the degree of reliance of either or both the supplier and the recipient on the intermediary in the course of providing a financial service referred to in any of paragraphs (a) to (i); • the intention of the intermediary to effect a supply of a financial service referred to in any of paragraphs (a) to (i); and • the normal activities of an intermediary in a given industry (including whether the intermediary is engaged in business of providing financial services). ... Based on the information provided, [Corporation A's] activities when considered as a whole are predominantly promoting and marketing the Program. ... Also [Corporation A] is not in the business of providing supplies of financial services or considered a financial intermediary as described under subparagraph 149(1((a)(iii). ...

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. ... In determining if an intermediary's service is included in paragraph (l), all the facts surrounding the transaction, including the following factors, must be considered: • the degree of direct involvement and effort of the person in the provision of a financial service referred to in any of paragraphs (a) to (i); • the time expended by the intermediary in the provision of a financial service referred to in any of paragraphs (a) to (i); • the degree of reliance of either or both the supplier and the recipient on the intermediary in the course of providing a financial service referred to in any of paragraphs (a) to (i); • the intention of the intermediary to effect a supply of a financial service referred to in any of paragraphs (a) to (i); and • the normal activities of an intermediary in a given industry (including whether the intermediary is engaged in a business of providing financial services). ...

Member will be considered a [...] fee and not the remittance of a portion of the membership fee collected by [Associations B] from the individual [...]. 26. ... Generally, activities carried out by a non-profit organization on behalf of a broad public sector so that both members and non-members alike benefit in a roundabout or secondary manner will be considered to be an indirect benefit. On the other hand, where the activities are directly aimed at benefiting only the members of a particular organization, then the activities will generally be considered a direct benefit. ...

It is your view that the scenario is analogous to the situation of a trade-in with a lien in that the buyout of the existing lease and subsequent sale, at a loss, should be considered a separate financing transaction. ... TIB B-084 states: "Where a lessee is obligated under the terms of a lease agreement to pay the lessor for any shortfalls below the guaranteed amount in the vehicle's value at the termination of the lease period, any shortfall in that amount is considered for GST/HST purposes to be additional consideration paid in respect of the vehicle. ... It is your view that the scenario is analogous to the situation of a trade-in with a lien in that the buy out of the existing lease and subsequent sale, at a loss, should be considered a separate financing transaction. ...

Also, where an organization is governed by provincial legislation respecting vocational schools, this will be considered an indication that one of the main purposes of the organization is to provide vocational training. ... Therefore, we can advise that this criteria is met. (3) Develop or Enhance Occupational Skills To be considered a vocational school, the courses offered by the organization must develop or enhance students' occupational skills. ... An individual course is considered to attest to the competence to practise a trade or vocation if: (i) the course is offered as a credit in a full-time program offered by the same institution; and (ii) the full-time program is offered on a pass/fail basis, based on the evaluation of the student's performance on a single, or series of, tests, graded materials or projects. ...

Also, where an organization is governed by provincial legislation respecting vocational schools, this will be considered an indication that one of the main purposes of the organization is to provide vocational training. ... Therefore, we can advise that this criteria is met. (3) Develop or Enhance Occupational Skills To be considered a vocational school, the courses offered by the organization must develop or enhance students' occupational skills. ... An individual course is considered to attest to competence to practise a trade or vocation if: (i) the course is offered as a credit in a full-time program offered by the same institution; and (ii) the full-time program is offered on a pass/fail basis, based on the evaluation of the student's performance on a single, or series of, tests, graded materials or projects. ...

The GST consequences of each of these transfers are considered below, followed by an explanation of the GST treatment of the ultimate sale of the Building Lots by B. ... Since the Complex was used by B solely as a place of residence, XXXXX would not be considered to be a "builder" (Paragraph (f) of the definition of "builder" (section 123(1) of the ETA) excludes an individual who acquires a residential complex or interest therein otherwise than in the course of a business or an adventure or concern in the nature of trade.) for purposes of the ETA. ... The respective interests of B and W in the Property were therefore considered to be real property for GST purposes. ...

Paragraph 131(1)(c) provides in part that where an amount is deducted from the fund and if the amount is in respect of a service the fund is considered to have acquired from the insurer, that supply of the service is deemed to be a taxable supply and the amount shall be deemed to be consideration for that supply. ... Further, subparagraph 131(1)(c)(i) generally provides that where an amount is deducted from the segregated fund, and that amount is in respect of a supply of property or a service that the fund is considered to have acquired from the insurer, that supply is deemed to be a taxable supply and the amount deducted is deemed to be consideration for that supply. Subparagraph 131(1)(c)(ii) generally provides that if the amount deducted from the fund is not in respect of property or a service considered to have been acquired from the insurer or another person, the insurer is deemed to have made, and the fund to have received, a taxable supply and the amount deducted is deemed to be consideration for that supply. ...