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GST/HST Ruling

24 September 1999 GST/HST Ruling HQR0001683 - Application of the GST/HST to Acting Courses Offered by a Vocational School

Also, where an organization is governed by provincial legislation respecting vocational schools, this will be considered an indication that one of the main purposes of the organization is to provide vocational training. ... Therefore, we can advise that this criteria is met. (3) Develop or Enhance Occupational Skills To be considered a vocational school, the courses offered by the organization must develop or enhance students' occupational skills. ... An individual course is considered to attest to the competence to practise a trade or vocation if: (i) the course is offered as a credit in a full-time program offered by the same institution; and (ii) the full-time program is offered on a pass/fail basis, based on the evaluation of the student's performance on a single, or series of, tests, graded materials or projects. ...
GST/HST Ruling

24 September 1999 GST/HST Ruling HQR0001748 - Application of the GST/HST to Acting Courses Offered by a Vocational School

Also, where an organization is governed by provincial legislation respecting vocational schools, this will be considered an indication that one of the main purposes of the organization is to provide vocational training. ... Therefore, we can advise that this criteria is met. (3) Develop or Enhance Occupational Skills To be considered a vocational school, the courses offered by the organization must develop or enhance students' occupational skills. ... An individual course is considered to attest to competence to practise a trade or vocation if: (i) the course is offered as a credit in a full-time program offered by the same institution; and (ii) the full-time program is offered on a pass/fail basis, based on the evaluation of the student's performance on a single, or series of, tests, graded materials or projects. ...
GST/HST Interpretation

27 June 2000 GST/HST Interpretation 30153 - Definition of "Residential Unit" and Application of Paragraph 6(b)/I/V

(a) He is not in agreement with our conclusion that a part of a residence room or apartment cannot be considered to be a residential unit because of the inclusion of the phrase "or that part thereof" in the definition of "residential unit" in subsection 123(1) of the ETA. ... In our ruling, we took the position that a room or apartment with more than one bed cannot be considered to be more than one residential unit as it is not possible to define exactly, or even roughly, the boundaries of each since they share, at least, the common space not occupied by the beds. ... To be considered a "residential unit" as defined, the part of the room or part of the suite in the hotel or motel must meet any one of the "structural" components described in paragraphs (a) to (c) as well as any one of the "functional" components in paragraphs (d) to (g). ...
GST/HST Interpretation

22 January 2001 GST/HST Interpretation 6309 - Sections 1 and 8 of Part III of Schedule V to the Excise Tax Act

Also, where an organization is governed by provincial legislation respecting vocational schools, this will be considered an indication that one of the main purposes of the organization is to provide vocational training, although it is not conclusive evidence. ... The enclosed policy statement provides that "... if an organization meets the 'operated primarily' requirements in its previous fiscal year, and its intent continues to be to primarily offer courses that develop or enhance students' occupational skills, it will be considered a vocational school for the following fiscal year (emphasis added)." In other words, if it meets this revenue based test in 1998, for example, it will be considered a vocational school for its 1999 fiscal year. ...
GST/HST Interpretation

3 December 2002 GST/HST Interpretation 39421 - Tax Status of Supplies Provided Via the Internet

Interpretation Given Based on the information provided, the supplies of data backup and recovery, Web page design and general consulting are considered by the Canada Customs and Revenue Agency (CCRA) to be supplies of services for GST/HST purposes. ... Where paragraphs 2(a) and 2(b) of Part V of Schedule IX to the ETA fail to determine the place of supply of a service in a particular province, the supply may be considered to be made in a particular province pursuant to section 3 of Part V of Schedule IX to the ETA. ... With respect to XXXXX supply of a data backup and recovery service, this service is considered to be a supply of a "computer-related service" for purposes of the place of supply rules. ...
GST/HST Interpretation

5 June 2003 GST/HST Interpretation 41495[2] - Outbound Postage and Handling Service Charges

Where the facts demonstrate that the Company is contracted to supply the service of applying postage to an Item that is prepared by another person, and the company subsequently delivers the Item to XXXXX for distribution XXXXX, the Company would be considered to be supplying a freight transportation service. Where the Company provides handling services e.g. loading, unloading, etc. with the postage, the handling services would be considered part of the freight transportation service if they are reasonably necessary for or incidental for the Item's transportation. ... In such a case, the postage and handling is considered an input into the overall processing service and would take on the same tax status as the service, notwithstanding the destination of the Item. ...
GST/HST Ruling

18 June 2003 GST/HST Ruling 37709 - Severance

The GST consequences of each of these transfers are considered below, followed by an explanation of the GST treatment of the ultimate sale of the Building Lots by B. ... Since the Complex was used by B solely as a place of residence, XXXXX would not be considered to be a "builder" (Paragraph (f) of the definition of "builder" (section 123(1) of the ETA) excludes an individual who acquires a residential complex or interest therein otherwise than in the course of a business or an adventure or concern in the nature of trade.) for purposes of the ETA. ... The respective interests of B and W in the Property were therefore considered to be real property for GST purposes. ...
GST/HST Ruling

25 April 2023 GST/HST Ruling 202403 - Eligibility for employer to claim ITCs on amounts related to investment management services for pooled funds of an insurer

Paragraph 131(1)(c) provides in part that where an amount is deducted from the fund and if the amount is in respect of a service the fund is considered to have acquired from the insurer, that supply of the service is deemed to be a taxable supply and the amount shall be deemed to be consideration for that supply. ... Further, subparagraph 131(1)(c)(i) generally provides that where an amount is deducted from the segregated fund, and that amount is in respect of a supply of property or a service that the fund is considered to have acquired from the insurer, that supply is deemed to be a taxable supply and the amount deducted is deemed to be consideration for that supply. Subparagraph 131(1)(c)(ii) generally provides that if the amount deducted from the fund is not in respect of property or a service considered to have been acquired from the insurer or another person, the insurer is deemed to have made, and the fund to have received, a taxable supply and the amount deducted is deemed to be consideration for that supply. ...
GST/HST Interpretation

23 July 2023 GST/HST Interpretation 244796 - Sale of vintage goods [through distribution platforms]

Under the new digital economy provisions and more specifically pursuant to subsection 211.23(1), if a distribution platform operator (Footnote 1) is registered for GST/HST purposes, […] the distribution platform operator is considered to be the supplier in respect of the supply of goods (Footnote 2) made by non-registered vendors that are facilitated through their platform (Footnote 3). ... Any proposal to change the legislation, including the rules related to digital platforms collecting the GST/HST on behalf of the vendors using the platform, must be considered by the Minister of Finance and approved by Parliament. ... Once a person's total taxable revenue exceeds $30,000 in the previous four consecutive calendar quarters, or in a particular calendar quarter, the person is no longer considered to be a small supplier and is then required to register for GST/HST purposes. ...
Archived CRA website

ARCHIVED - Patronage Dividends

A taxpayer is considered to qualify in "allocating in proportion to patronage" even though, for reasons of convenience, credit is not given to those customers to whom the patronage allocation would be less than $5.00, provided all other conditions are met. ... Payments may also be made in accordance with the terms and conditions of a contract, or in compliance with the terms of the taxpayer's charter, articles of association, or by-laws, which would not be considered to be patronage dividends. ... In all cases where payment has been effected by the payer in any manner whatsoever, the patronage dividend is considered to have been received by the customer. 15. ...

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