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Products that are labelled and/or marketed for the consumption of certain ingredients (nutritive or otherwise), or products that place emphasis on the perceived benefits of consumption (for example, therapeutic or preventative effects, or enhancing performance or physique) are not considered products that an average consumer would ordinarily purchase in the course of buying food or beverages. Products of this sort are considered dietary supplements and are consumed for actual or perceived health benefits. ... Although these products may contain some essential nutritional elements, they are not considered to be basic groceries. ...

Based on the information provided, the Product is considered a fruit bar and excluded from zero-rating by virtue of paragraph 1(l) of Part III of Schedule VI to the ETA. ... Further information is found in paragraph 65 of Memoranda Series 4.3, which states bars that contain a mixture of cereals and honey and/or syrup, where the ingredients have been processed to the point that they have lost their distinct character, are not considered granola bars, but rather cereal bars or muffin bars. Considering that the Product's main ingredient is fruit, and that it does not contain cereal, and is not marketed as a cereal bar, it is not considered to be a cereal bar for purposes for paragraph (h). ...

The Corporation is considered a large business for purposes of the RITC rules and may be subject to RITCs if the supply of utilities by the landlords is considered to be a separate supply of specified energy. ... Section [...] of Article [...] further states that all amounts payable under the lease, other than the basic rent, are considered "Additional Rent". ... The charges for utilities (heat and electricity) that are billed to the Corporation by their landlords or the utility companies are considered additional rent under the respective lease agreements. ...

Based on the facts, the Supplier is not considered to have obtained an address of the recipient when the right to access and use the content on the Website is granted to the recipient. An IP address is not considered to be an address of the recipient. The type of address obtained for purposes of the rule must be an address of the recipient that represents a specific physical location that is situated in a province. For instance, an e-mail address or an IP address obtained by a supplier that does not represent an actual specific physical address is not considered to be an address for purposes of the rule. ...

The service provided by XXXXX is not considered to be a freight transportation service by definition of that term. ... The supply of transporting XXXXX is considered to be a supply of a freight transportation service. ... It is important to note that the decision in the Bam Packaging Ltd. case is not considered to be precedent-setting as it was heard under the Informal Procedure of the Tax Court. ...

Moreover, in order to be regarded as an ingredient to a food or beverage, the final product, in and of itself, must be considered to be a food or beverage by the average consumer. Additionally, a product that is marketed for its beneficial effects, and that is added to a food or beverage simply as a means of consuming it, would not be considered as an ingredient to a food or beverage simply because it is ingested in this manner. Among other factors, the CRA will consider labelling, packaging and marketing to determine whether a product would be considered a "food", "beverage", or "ingredient". ...

This particular wine kit is considered to be a single supply of ingredients to make wine. The presence of the labels, corks and shrink capsules does not alter the essential character of the main supply, which again, is considered to be a kit containing ingredients to make wine. ... Analysis pursuant to Policy P-077R focuses on three key questions and these are considered in this case, as follows: 1. ...

Based on the facts referred to above, the mini-home is considered to be a residential unit. ... As such, the unit is considered to be a residential unit that is affixed to the land. ... A residential unit that is affixed to the land may be considered to be a place of residence based on the purpose for which it was affixed to the land, as well as the length of time and the frequency throughout the year that the individual occupying the unit is physically present and using the unit as a place of residence. ...

RULING REQUESTED You would like to know the province in which the supplies of the goods made by [the Supplier] to [the Subsidiary] and [Company A stores] as described in the facts are considered to be made. ... It is at the [Company B] warehouse that has been hired by [the Subsidiary], and beyond which [the Subsidiary] arranges for the shipment of the goods to the [Company A stores] on their behalf, that possession of the goods supplied by [the Supplier] is considered to have transferred. ... Depending on the facts in these other circumstances, the supply of the goods could be considered to be made in the province in which the [Company A stores] that is specified in the purchase order is located. ...

XXXXX is not otherwise one of the organizations excepted from being considered a non-profit organization under the ETA. 2. ... 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.... ... For fiscal years ending in XXXXX, our review of the statutory mandate and the contents of the Annual Reports confirm that XXXXX: • Is not an organization who is specifically excluded from being considered a non profit organization; • Is considered to be a person organized solely for a purpose other than profit; • With no part of its income payable or otherwise available for the personal benefit of any member; and • It operated for a purpose other than profit. ...