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GST/HST Interpretation
8 August 2012 GST/HST Interpretation 124636 - The status of supplies of nursing services
Based on the information provided, we understand the following: 1) You are a […] registered nurse. […]. 2) In [yyyy], you began your own business, […], as a health promotion consultant. 3) As a consultant, your work focused mainly on […]. 4) As a health promotion consultant, your client groups were populations in settings such as schools, other community organizations and agencies addressing primary prevention with vulnerable groups such as […]. 5) In your work as a consultant, you provided interventions such as health teaching and health promotion, communicating with individuals, families, groups, communities and populations, collaborating with care providers, directly or indirectly influencing the practice of care providers and/or policy, developing learning resources for nurses and other care providers and collecting health data, specifically as they supported health promotion work with vulnerable or at-risk populations for […]. 6) Also, you […], developed, […] to support information and awareness related to […] lifestyle risks, and so that several health promotion strategies could be employed by public health nurses […] 7) As a health promotion consultant, you also developed training resources for nurses to use with community health center staff regarding health issues, […]. ... Other activities which the CRA interprets as not involving such services are communicating with communities or populations, managing nursing resources such as staff, facilities and equipment, developing learning resources for nurses and other health care providers, and providing or developing health education for organizations. ... More specifically, you developed, […] programs. These programs were developed to support information and awareness related to, for example, […] and lifestyle risk factors, […] These programs were for the most part to be delivered by health care providers such as nurses. ...
GST/HST Interpretation
20 July 2012 GST/HST Interpretation 142010 - Pension plans
. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... Legislation A “participating employer” of a pension plan that is a GST/HST registrant is generally deemed to have made a taxable supply where, * under subsection 172.1(5), the employer acquires a particular property or a service (i.e., a “specified resource”) for the purpose of re-supplying some or all of that property or service to a pension entity for consumption, use or supply by the pension entity in the course of pension activities of the pension plan; * under subsection 172.1(6), the employer consumes or uses an “employer resource” (Footnote 1) for the purpose of making a supply of property or a service to a pension entity for consumption, use or supply by the pension entity in the course of pension activities in respect of the pension plan; and * under subsection 172.1(7), the employer consumes or uses an “employer resource” in the course of pension activities of the pension plan and the consumption or use is not for the purpose of making a supply of property or a service to the relevant pension entity. ... The amount of tax deemed collected is, generally speaking, calculated on the fair market value (FMV) of the employer resource or specified resource in question. ...
GST/HST Interpretation
12 April 2012 GST/HST Interpretation 141971 - Supplies by a participating employer of a pension plan
An employer, located in Ontario, maintains […] pension plans for its employees. 2. ... Issue 2: Application of section 172.1 As you are aware, a “participating employer” of a pension plan that is a GST/HST registrant is generally deemed to have made a taxable supply where, * under subsection 172.1(5), the employer acquires a particular property or a service (i.e., a “specified resource”) for the purpose of re-supplying some or all of that property or service to a pension entity for consumption, use or supply by the pension entity in the course of pension activities of the pension plan; * under subsection 172.1(6), the employer consumes or uses an “employer resource” for the purpose of making a supply of property or a service to a pension entity for consumption, use or supply by the pension entity in the course of pension activities in respect of the pension plan; and * under subsection 172.1(7), the employer consumes or uses an “employer resource” in the course of pension activities of the pension plan and the consumption or use is not for the purpose of making a supply of property or a service to a pension entity. ... However, based on current provisions of the ETA, subsections 172.1(5) and (6) will generally apply where specified resources and employer resources (collectively the “resources”) are acquired, used or consumed by an employer for supply to a “pension entity” (Footnote 1). ...
GST/HST Interpretation
28 April 2000 GST/HST Interpretation 13392 - Sale of 311 Acres of Forested Land -
"the proper way to manage and conserve a forest" from the point of view of improving or maintaining the forest as a commercial resource). ... GST/HST Memoranda Series Chapter 1.4, " Goods and Services Tax Rulings ", provides for circumstances where rulings should not be issued. ... Such an interpretation could provide a general discussion on the concept of a reasonable expectation of profit and the inclusion of policy P-176R, " Application Of Profit Test To Carrying On A Business ", in the response to the client. ...
GST/HST Interpretation
28 October 1998 GST/HST Interpretation HQR0001314 - Tax Status of Observer Services Supplied by Public Sector Companies to Resident and Non-resident Fishers
., XXXXX to XXXXX, but only for the specific resources related purposes set out in the subsection, that is, activities related to mineral exploration and exploitation, and not other activities, such as fishing or fish processing. ... In all three definitions, references are made to the Canada-Newfoundland Atlantic Accord Implementation Act or the Canada-Nova Scotia Offshore Petroleum Resources Accord Implementation Act. XXXXX Both of the aforementioned acts deal with offshore petroleum resource management and revenue sharing. ...
GST/HST Interpretation
6 June 1995 GST/HST Interpretation 11635-8 - Information Concerning the Interpretation of Section 273 of the Excise Tax Act in Respect to the Assignment of a Joint Venture Interest from
The principal components of the project were: • the study of the haor areas in the district for the purpose of defining a regional development strategy as well as design criteria for the execution of flood control, drainage and irrigation development; • an agriculture assistance program to provide technical assistance to the organization responsible for the delivery of agricultural extension services; • a human resource development program which will offer instruction to farmers on how to form cooperatives and provide them with the opportunity to acquire farm and water management knowledge; • a training program to enhance the technical, managerial and administrative skills of the organizations involved in the project; and • design, procurement and construction services of civil works. 4. ... A joint venture will exist where the parties intended to form a joint venture which is not a partnership, and: • they did not form a new entity or person; • the joint venture has no legal status and is not autonomous; • the joint venture does not have a separate name which is registered under the Civil Code; • the joint venture does not have its own funds, its own bank account, its own management committee and its own accounting system; • the joint venture has no estate and cannot transact (e.g., cannot purchase and dispose of property); • the participants individually or jointly carry out the transactions necessary to realize the joint venture's objectives; and • the joint venture contract, like a contract for a partnership, requires the contribution of property, credit, skill or industry, as well as the sharing of profits and losses. ... Funk & Wagnalls' Standard College Dictionary: "the business of operating a farm, agriculture" where a farm is defined as "a tract of land forming a single property and devoted to agriculture" and agriculture is defined as "the cultivation of the soil; the raising of food crops, breeding and raising of livestock, etc.; tillage"; 2. ...
GST/HST Interpretation
27 November 2013 GST/HST Interpretation 152148 - New GST/HST rules on deemed supplies of property and services to pension entities
The employer charges the pension entity for the services of one full-time employee who is responsible for: * union negotiations; * selecting, monitoring and evaluating a fund manager; and * producing information material to members. ... For purposes of subsection 172.1(6), or (7), an "employer resource" is essentially anything (other than an excluded resource) acquired, created, developed and/or produced by the employer including the employee labour and overhead required to do these things. Whether an employer is deemed to have made a taxable supply and collected tax under any of subsection 172.1(5), (6) or (7) is contingent on whether the particular specified resource or employer resource is for consumption, use, or supply, in the course of "pension activities" in respect of the pension plan. ...
GST/HST Interpretation
9 August 2010 GST/HST Interpretation 114093r - Tax Status of Supplies of Nursing Services
Given the preceding, there are three criteria that the supply must meet to be exempt; i.e., it must be a service that: • is rendered by a registered or licensed nurse; • falls within the scope of nursing services; and • is rendered to an individual within a nurse-patient relationship. ... Generally speaking, a case manager works in collaboration with service providers to link clients with appropriate providers and resources. ... Case management activities may include: • assessment of the individual to identify the individual's needs in order to develop a comprehensive case management plan that will address those needs; • determining and documenting the objectives, goals, and actions designed to meet the individual's needs as identified in the assessment process; • implementing and documenting activities and interventions of the case management plan; • coordinating, securing, modifying and documenting the resources relating to the case management plan; • monitoring by gathering information from relevant sources, activities and services to determine the effectiveness of the case management plan; and • measuring the interventions to determine the outcomes of the case management plan, such as the individual's quality of life and satisfaction. ...
GST/HST Interpretation
25 June 2024 GST/HST Interpretation 246382 - Mining activities in respect of cryptoassets concerning mining pools
Accordingly, our comments below are limited to those circumstances. […]. ... A CSP receives payment in the form of [cryptoasset] based on the estimated revenue calculation […]. ... In a FPPS payment arrangement, generally the Operator bears the risk associated with mining a block […]. ...
GST/HST Interpretation
9 April 2025 GST/HST Interpretation 247209 - Mining activities in respect of cryptoassets after February 4, 2022 via mining pools
A CSP contributing computing resources to a mining pool operated by Company F in exchange for payments in the form of PPS+. […]. ... Accordingly, our comments below are limited to those circumstances. […]. ... A CSP receives payment in the form of [cryptoasset] based on the estimated revenue calculation […]. ...