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GST/HST Ruling
17 January 2012 GST/HST Ruling 131923 - GST/HST Ruling - Tax Status of Supplies made by a Municipality
Section 1 of Part VI of Schedule V outlines the criteria that must be met for an organization to be a para-municipal organization of a municipal body that is a municipality: (a) The organization must be owned or controlled by the municipal body; and (b) The organization must be designated under section 259, or under section 22 or 23 of Part VI of Schedule V, to be a municipality, or established by the municipality and determined under paragraph (b) of the definition "municipality" in subsection 123(1) to be a municipality for the purposes of Part IX; or For the above purposes, an organization will be considered to be owned by a municipality if: • The municipality owns 90% or more of the shares or capital of the organization; or • The municipality owns the organization's assets or having control of the disposition of the organization's assets so that the assets are vested in the municipal body in the event that the organization is wound-up or liquidated. For the above purposes, an organization will be considered to be controlled by a municipality if: • the municipality appoints more than 50 percent of the members of the governing body of the organization (e.g., directors, governors, commissioners); and • the municipality is responsible for reviewing and approving the organization's operating and capital budgets. ...
GST/HST Ruling
27 August 2010 GST/HST Ruling 125336 - Application of GST/HST to Services Provided for a Finder's Fee
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). ...
GST/HST Ruling
23 February 2010 GST/HST Ruling 86356 - New Residential Rental Property Rebate Eligibility
" As such, a person will be considered a "builder" of the complex if the person acquires an interest in a residential complex, before it is occupied as a place of residence or lodging, for the primary purpose of selling the complex, or an interest in the complex. ... While you are required to repay the overpayment of the rebate as referred to above, you are not considered to be a "builder" of the complex and as such are not required to remit GST/HST on the sale of the Unit. ...
GST/HST Ruling
19 January 2011 GST/HST Ruling 123253 - Services provided by [...] [Company A] to [...] [Company B]
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, while some of [Company A's] Program related activities, such as assisting with the completion of the applications and the verification of the identity of the Applicants, assist [Company B] in providing a financial service of granting credit to an Applicant, [Company A's] activities when considered as a whole are predominantly promoting and marketing the Program. ...
GST/HST Ruling
5 January 2022 GST/HST Ruling 197277r - […][Supplies of acne scar treatments]
., nor to treat a medical condition, would be considered to be provided for cosmetic purposes only and, therefore, section 1.1 of Part II of Schedule V would apply, and the service would not be exempt under section 7 of Part II of Schedule V. ... Where a procedure meets the guidelines of the province the procedure would be considered to be done for medical or reconstructive purposes regardless if the procedure was covered by the provincial health care plan or not. ...
GST/HST Ruling
1 September 2005 GST/HST Ruling 63026 - ITC eligibility in respect of coupon program
., the distinct areas of the parcel are dedicated exclusively to one use at all times), the space-based method cannot be considered unreasonable unless it can be shown that a unit of space is not a consistent measure of the extent to which the parcel is used in commercial activities. ... If this is not the case, because one space is improved to a significantly greater extent than the other, then the space-based method may be considered unreasonable on its own, justifying the introduction of their relative "value as improvements" as a factor to modify the space-based method. (2) Using time available for rent as a basis for determining the extent to which university residences are used in commercial activities. ...
GST/HST Ruling
11 July 2006 GST/HST Ruling 76850 - GST/HST Registration of XXXXX
The services of XXXXX are not considered to be XXXXX services to XXXXX and, therefore, do not qualify for XXXXX Membership. 12. ... As such, this benefit could not be considered a secondary or unintended consequence of membership and is therefore not an indirect benefit. ...
GST/HST Ruling
29 November 2007 GST/HST Ruling 95098 - XXXXX – Eligibility of the XXXXX to claim the 83% public service body rebate
Can a trip with a stopover of more than 24 hours be considered two continuous journeys? ... A deposit made by credit or charge card is not considered to have been paid to the registrant until the issuer of the card credits the registrant's account. ...
GST/HST Ruling
3 April 2007 GST/HST Ruling 85543 - Independent Medical Examinations and Related Services
Accordingly, we considered how occupational therapy services are described in the XXXXX Occupational Therapy Act XXXXX as well as the services that are recognized by the College of Occupational Therapists XXXXX. ... After consultation with members of the health care community and the insurance industry, the CRA released GST/HST Policy Statement P-248 to announce its change in position that for purposes of the exemptions in sections 5 and 7 of Part II of Schedule V, independent assessments (including independent occupational therapy assessments) would be considered a service rendered to an individual, notwithstanding that these assessments do not include a therapeutic or treatment component of the individual and that these assessments are done at the request of an insurer or other third party. ...
GST/HST Ruling
26 February 2007 GST/HST Ruling 79576 - Application of GST/HST to supplies of emu fat, and emu oil for topical purposes
We understand that it is your view that the phrase XXXXX in the definition above encompasses all that can be considered to be involved in the practice of the science of food and human nutrition, which includes the making use of, or employing, the specialized body of knowledge concerned with food and human nutrition. ... Since the services in question are supplied in XXXXX, we considered the manner in which dietetic services are defined by the legislation and regulations of that province XXXXX. ...