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., 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. ...

A facility or part of a facility will be considered a qualifying facility if: (a) supplies of services that are ordinarily rendered during that fiscal year or part to the public at the facility or part would be facility supplies if the references in the definition of "facility supply" in subsection (1) to "public hospital or qualifying facility" were references to the facility or part; (b) an amount, other than a nominal amount, is paid or payable to the operator as qualifying funding in respect of the facility or part for the fiscal year or part; and (c) an accreditation, licence or other authorization that is recognized or provided for under a law of Canada or a province in respect of facilities for the provision of health care services applies to the facility or part during that fiscal year or part. ... In addition, because XXXXX does not make facility supplies, the facts respecting the receipt of government funding has not been considered for purposes of establishing whether it meets the requirements described in subsection 259(2.1) for qualifying facilities. ...

A facility or part of a facility will be considered a qualifying facility if: (a) supplies of services that are ordinarily rendered during that fiscal year or part to the public at the facility or part would be facility supplies if the references in the definition of "facility supply" in subsection (1) to "public hospital or qualifying facility" were references to the facility or part; (b) an amount, other than a nominal amount, is paid or payable to the operator as qualifying funding in respect of the facility or part for the fiscal year or part; and (c) an accreditation, licence or other authorization that is recognized or provided for under a law of Canada or a province in respect of facilities for the provision of health care services applies to the facility or part during that fiscal year or part. ... However, as there is no indication in the facts presented above that the Centre makes ancillary supplies or home medical supplies, we have not considered its eligibility for an 83% PSB rebate in respect of these supplies. ...

Subsection 3(1) of the IFTA Reg. states: "for the purposes of subsection 4.13(1) of the Act, a licencee, when operating an inter-jurisdictional vehicle, is considered to be registered with the Minister, but only if the licencee, (i) affixes the registration decals or carries a 30-day IFTA temporary permit issued by a base jurisdiction other than Ontario as required under Part VI of the Articles of Agreement under the IFTA; and (ii) places in the motor vehicle the IFTA licence issued to the licencee, or a legible copy of the licence, as required under Part VI of the Articles of Agreement of the IFTA. ... Reg. 22/97, a carrier is considered registered with the Minister for purposes of the regulatory framework and the IFTA, only if it displays a registration certificate and a set of decals in each qualifying vehicle. ...

Gross revenue includes business income, donations, grants, gifts, property income, investment income and any amount considered a capital gain less any amount considered a capital loss from the disposal of property for income tax purposes. ...

Rather, the certificates entitle the purchaser to monetary discounts and offer items for no charge if another item is purchased; therefore, the certificates are not considered to be gift certificates. ... As the certificates do not offer a reduction equal to fixed dollar amount or fixed percentage amount, the certificates are not considered to be "non-reimbursable coupons" under subsection 181(3). ...

An entity that does not meet all of these requirements will not be considered to be making facility supplies and therefore would not qualify as a "facility operator". ... Since XXXXX does not make facility supplies, the facts respecting the receipt of government funding have not been considered for purposes of determining whether it meets the other requirements with respect to qualifying facilities. ...

The factors that will be considered in determining whether a non-resident person is carrying on business in Canada for GST/HST purposes in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed; and •   the place of manufacture or production. ... Generally, a non-resident person must have a significant presence in Canada to be considered to be carrying on business in Canada. ...

However, if the personal hygiene activities and assistance with activities of daily living were incidental to, or formed part of, a supply of a homemaker service and were provided together for a single consideration, it is CRA's view that the personal hygiene activities would be considered a homemaker service. ... As indicated above, personal hygiene activities are not considered a homemaker service unless they are incidental to, or formed part of, a supply of a homemaker service. ...