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The payments from XXXXX to the City are considered to be merely a transfer of funds. ... The Department is prepared to accept, on an administrative basis, that in those situations where the election has not been filed but the supplier has been charging GST, the election will be considered to be in effect from the date that the amounts on or account of tax became payable or were paid. ... Where a profit is realized on the operation of the XXXXX and the City pays the agreed portion of the profits to XXXXX (as per Statement of Facts- item #12) this amount is considered to be further consideration in respect of the taxable supply of operational and management services in respect of the XXXXX and will attract GST at 7%. ...

In addition, sections 1.1 and 1.2 of Part II of Schedule VI must also be considered when making a determination as to whether or not a particular supply of a medical and assistive device is zero-rated. ... This section clarifies that a cosmetic service supply, and a supply of any property or service in respect of a cosmetic service supply that is not made for medical or reconstructive purposes, are not considered basic health care and are excluded from the exempting provisions (other than section 9) in Part II of Schedule V. ... Crowns that are fabricated to replace 50% or more of existing natural teeth are considered to be artificial teeth for purposes of the zero-rating provision. ...

The Association’s main office is located in [City 1] and would be considered a fixed place of activities as it is a determined location that can be identified with the Association, and the Association exercises control over that office and carries out its on-going charitable activities through that office on a regular and reoccurring basis. At the same time, the premises of the Members cannot be considered as fixed place of activities of the Association since, based on the available information, Members are independent in their daily operations, separate legal entities, and as stated in the Member Agreement, “the Members shall each have exclusive authority, control and responsibility for the Member’s activities within its territory…” However, there are other circumstances set out in subsection 400(2) of the Income Tax Regulations where a charity may be deemed to have a “permanent establishment” in a province. ...

To arrive at this conclusion, we considered information obtained from your letter, phone conversations with you, the sample agreement you have with parents/guardians, and the […][guidelines and mutual expectations between the parties]. ... There are numerous work elements, such as training or instruction, included as part of this overall supply of training plan/program design, however, we do not consider that these individual tasks or elements carry sufficient weight on their own to warrant being considered separate supplies. ...

The business addresses obtained include the address of the [contractor] in [Province 3], which is considered to be the contracting address and consequently the address that is most closely connected with the supply of the IPP. ... The business addresses obtained include the address of the [contractor] in [Province 3], which is considered to be the contracting address and consequently the address that is most closely connected with the supply of the [...] service and the optional [...] service. ...

Section […] of the Lease Agreement states that all amounts which are payable by the Tenant to the Corporation pursuant to the lease shall be considered to be rent and all remedies from time to time available to the Corporation for the collection of rental shall apply. 13. ... The Tenant's reimbursement of municipal property taxes, and any other taxes or levies applicable to the Premises is also considered additional rent under the Lease Agreement. ...

EXPLANATION Upon entering into an agreement for the purchase and sale of a new residential condominium unit that has yet to be constructed, the purchaser is considered to have acquired an interest in the residential condominium unit. An assignment of such an agreement of purchase and sale is considered to be a supply by way of sale of the interest in the residential condominium unit. ...

We considered XXXXX status as a polysomnographic technologist. However, there is no exempting provision in the ETA for services supplied by a polysomnographic technologist whether the person holds a Registered Polysomnographic Technician Certificate issued by a college in Canada or is otherwise recognized by a law or regulatory body of a health care profession in Canada as a registered polysomnographic technician or technologist. We also considered whether the XXXXX payments made to the XXXXX for the PSG tests would impact the tax status of XXXXX supplies. ...