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As a result the Organization will be considered an NPO for purposes of section 259 where it meets the definition of NPO in subsection 123(1) when read without reference to a government. ...

To be considered a residential unit in this case, the room in the hospital must meet one of the "structural" components described in paragraphs (a) to (c) as well as one of the "functional" components in paragraphs (d) to (g). ...

RULING REQUESTED You would like to confirm that: 1. payments received by the Association from Partners that participate in the Program and who offer reward dollars to Association members represent consideration for the supply of a gift certificate and, as such, the Association is not required to collect GST/HST on the supply of the reward dollars; 2. when reward dollars are used by members to purchase property and services, the Association should treat the reward dollars as money; and 3. if the reward dollars are not considered a gift certificate, the non-reimbursable coupon rules in subsection 181(3) apply in situations where the Association treats the reward dollars as a “partial cash payment that does not reduce the value of the consideration for the supply” so as to allow the Association to claim an input tax credit (ITC) for the tax fraction of the reward dollars. ...

In determining if a service is included in paragraph (l) of the financial service definition, all of the facts surrounding the transaction must be considered. ...

Subsection 141.01(2) provides that the extent to which a property or service is considered to be acquired for consumption or use in a person's commercial activities is generally based on the extent to which the property or service is acquired for the purpose of making taxable supplies for consideration. ...

To arrive at this conclusion, we considered information obtained from your letters, our telephone conversation, and the Agreement you enter into with your clients. ... There are numerous work elements, such as training or instruction, included as part of this overall supply of services, however, we do not consider that these individual tasks or elements carry sufficient weight on their own to warrant being considered separate supplies. ...

Based on the information provided, the services that you supply to your clients would be considered nursing services for purposes of the ETA. ... It is important to note that not all case management services performed by a registered nurse would be considered to be nursing services for purposes of section 6 of Part II of Schedule V. ...

The issuance of a block of Shares is considered to be an element of this supply. ... As such, the Company is considered to be making a single supply of the land-use rights to a Shareholder. ...

., residential units) that must be considered in determining whether all or substantially all of the lessee's supplies of property are supplies of the complex that are exempt under section 6 of Part I of Schedule V to the ETA. ... If OPCO initiated the construction of a residential complex prior to leasing the real property to LESSEE, OPCO is also considered a builder for GST/HST purposes. ...

., residential units) that must be considered in determining whether all or substantially all of the lessee's supplies of property are supplies of the complex that are exempt under section 6 of Part I of Schedule V to the ETA. ... If OPCO initiated the construction of a residential complex prior to leasing the real property to LESSEE, OPCO is also considered a builder for GST/HST purposes. ...