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No […][GST/HST] was paid by the Corporation on the purchase of the lift and its installation, as they were considered to be zero-rated supplies. ... The interrelationships among the various elements of the agreement, the purpose of an agreement, the needs of the customer, and the economic reality of the agreement are among the factors considered to determine whether an agreement provides for a single supply or multiple supplies. ... As such, if the predominant element of the single supply is determined to be a particular service, then the GST/HST status of the supply as a whole will be considered to be that of the particular service. ...

Where the electronic book is not restricted from being used in Canada, the supply is considered to be made in Canada and the entire voluntary payment would be subject to GST/HST unless zero-rated. ... A supply of a digitized product made by electronic means is considered to be a supply of IPP for GST/HST purposes that would be a taxable supply when made by a person other than a registered charity. ... Under this provision, a supply of IPP (e.g., an electronic book) is considered to be made in a province if the place of negotiation of the supply is in the province and the IPP may be used otherwise than exclusively (i.e., 90% or more) outside the province. ...

., a monthly filer, may be considered to have filed the return in time for the reporting period ending on June 30, 1998, if it was filed on July 20, 1998, as required by subsection 238(1). ... TPR adjustments are not considered Tax Returns. For any subsequent amendments to the GST returns filed, your attention is drawn to GST Guide RC4022 General Information for GST/HST Registrants: "If you need to make a change to any return you have sent us, do not file another return. ... The transactions referred in situation 2 are considered wash transactions. ...

In examining the facts submitted, section 2 of Part I of Schedule V to the ETA must be considered to determine if XXXXX's supply of the New House is exempt. ... An individual who constructs a residential complex, or engages someone to construct the complex on land that they own is considered a builder within the meaning of "builder" set out in subsection 123(1), if the construction is made in the course of a business or an adventure or concern in the nature of trade of the individual. Where an individual constructs, or engages someone to construct, a residential complex on land that they own for his or her own personal use, without the primary or secondary intention of resale, the individual would not normally be viewed as constructing the complex in the course of a business or an adventure or concern in the nature of trade and such an individual would not be considered a "builder" within the meaning of the ETA. ...

Whether services performed by the Dealer for the Investment Manager are considered to be a single supply or multiple supplies is a question of fact. ... A service performed by a person that is the "arranging for" a financial service is also considered to be a financial service under paragraph (l) of the definition in subsection 123(1). ... In determining if an intermediary's service is included in paragraph (l), all of 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). ...

If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 must also be considered. ... 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. ... Under the Contract, the Administrator is considered to be providing a service to the Employer for which it receives an administration fee that is excluded from the definition of financial service since the Administrator is not a person at risk. ...

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, [Corporation A's] activities when considered as a whole are predominantly promoting and marketing the Program. ... Also [Corporation A] is not in the business of providing supplies of financial services or considered a financial intermediary as described under subparagraph 149(1((a)(iii). ...

If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 must also be considered. ... 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). ...

Improvements to capital real property The new recreational complex would generally be considered an improvement to the Property. ... Subsection 141.01(3) provides that a person is considered to use property (e.g., capital real property) in commercial activities only to the extent that the property is used for the purpose of making taxable supplies for consideration in the course of an endeavour of the person. ... While paragraph (c) of the description of element B in subsection 169(1) provides that the ITC is based on the extent of use of the property in commercial activities, the "primary use" rules in section 199 must be considered in determining the extent of use in commercial activities. ...

Member will be considered a [...] fee and not the remittance of a portion of the membership fee collected by [Associations B] from the individual [...]. 26. ... Generally, activities carried out by a non-profit organization on behalf of a broad public sector so that both members and non-members alike benefit in a roundabout or secondary manner will be considered to be an indirect benefit. On the other hand, where the activities are directly aimed at benefiting only the members of a particular organization, then the activities will generally be considered a direct benefit. ...