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Paragraph 1(n) of Part III of Schedule VI is the relevant exclusionary paragraph that needs to be considered. ...

The physicians are considered "primary care physicians". As primary care physicians, they service residents who come to the Facility in situations (90% overall through the years) where the resident’s family physician has not continued to service the resident once the resident has entered the Facility. ... The nursing portion of the Facility care is considered symptom management, including dealing with conditions such as loss of appetite, nausea, weakness, difficulty breathing, bowel and bladder problems and confusion. ... As mentioned above, subsection 259(2.1) sets out three criteria that must be met in order for a facility or part of a facility to be considered a qualifying facility for all or part of a fiscal year. ...

In providing our response, we have considered provisions in Schedule V that exempt certain supplies made by non-profit organizations. ... Insurance coverage is considered a direct benefit of membership that does not fall under paragraphs (a) to (f) of section 17 of Part VI of Schedule V. ... A supply of this nature is considered to be a supply of intangible personal property. ...

Where a program or package offers optional supplies of property or services, the program or package may generally be considered to consist of multiple supplies. ... The provision of the one supervised overnight sleepover will not exclude the supply from being exempt as one night in a 5-day weekly day camp program is not considered to be a substantial portion of the program. ... For information on what is considered a catering service, please refer to GST/HST Memoranda Series 4.3, Basic Groceries, beginning with paragraph 126. ...

A developmental disorder described in Fact #3 above is considered to be a "disorder or disability" for purposes of section 14. ... (i) [Activity A] For purposes of section 14 of Part II of Schedule V, a supply of [training] and support services, comprised of child behavioural management, [...], assistance with personal care, parent coaching and respite services, made under [Activity A] is considered to be a supply of a training service that consists of training that is specially designed to assist an individual with a disorder or disability in coping with the effects of the disorder or disability or to alleviate or eliminate those effects. ... (ii) [Activity B] For purposes of section 14 of Part II of Schedule V, a supply of [training] services made under [Activity B] is considered to be a supply of a training service that consists of training that is specially designed to assist an individual with a disorder or disability in coping with the effects of the disorder or disability or to alleviate or eliminate those effects. ...

With respect to the Set-Up Fees and other amounts that the Borrower is responsible for paying under the Loan Agreement, since each element is intricately linked to each other, it is determined that the Limited Partnership is providing a single supply to the Borrower, with the predominant element of the supply considered to be the lending of money (a loan) which is a financial service. ... As discussed in policy statement P-244 Partnerships- Application of subsection 272.1(1) of the Excise Tax Act, a number of factors must be considered. ... Where a corporate general partner of a limited partnership receives a fixed fee (for example, a percentage of the net value of partnership assets) for services it provides to the partnership, generally the amount would be considered to be remuneration for services provided by the general partner on its own account and not for something done as a member of the partnership even if the agreement to provide the services is included in the partnership agreement. [...] sets out that certain fees including all Set-Up Fees in excess of the aggregate of [...]% of the principal amount of all loans are paid to the Limited Partnership and then allocated/distributed to the Partners. ...

Specifically, the designs of the Units at issue depict what would be considered "typical" residential layouts for condominium units of their size, and any areas specifically identified as "work" are generally commensurate in dimension and location with what might otherwise be designated a second bedroom or den. ... Where the fair market value of the Unit must be apportioned between the portion of the Unit that is considered to be a residential complex and the portion that is not part of the residential complex, the apportionment must be fair and reasonable. ... Generally, in this case, it would appear that the allocation for a particular Unit would remain fairly constant over time; however, if XXXXX becomes aware of an increase or decrease in the use of a Unit by a tenant, XXXXX may be considered to have accepted such a change. ...

Because the Association calculated its tax liability on XXXXX, it is considered to have reported and remitted an excess amount as or on account of tax for this transaction. ... Personal property that is acquired or imported for use by a registrant as capital personal property primarily in commercial activities of the registrant is considered to have been acquired or imported for use exclusively in commercial activities. Conversely, where the capital personal property is for use less than primarily in commercial activities, the registrant is considered to have acquired the property for use exclusively in non-commercial activities. ...

Given that no exemptions or other relieving provisions applied, the XXXXX are considered to have made taxable supplies to CanCo under the Licence Agreement and under the Lease. ... As explained above, the XXXXX, as joint tenants, are considered to have made a separate supply of the Lands for each lease interval under the Licence Agreement and under the Lease. ... In other words, subsection 141.01(7) ensures that, for purposes of claiming ITCs, the supplies made by the XXXXX under the Lease are considered supplies, and the consideration payable by CanCo is recognized as consideration. ...

You also advised that there are no RVs on the sites that have been modified to such an extent that they would be considered similar to a house, mobile home or other residential unit. 11. ... Supply under Head Lease Subsection 136(2) provides, in part, that where a supply of real property includes land that forms part of a residential complex and other real property that does not form part of such land, the supply of the land that forms part of the residential complex and the supply of the remaining real property are considered to be separate supplies and neither supply is incidental to the other. The supply of land that forms part of the condominium units is, on the assumption that the condominium units are residential complexes, considered to be a separate supply from the rest of the supply of the Property made under the Head Lease. ...