Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

4 April 1996 GST/HST Interpretation 11680-1[5]- Supplies by Mail Order Unedited CRA Tags ETA 142; ETA 143; ETA Sch VI, Part V, 12                                                                         Telephone #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         File #: 11680-1(glr)                                                                         s. 142, 143 Sch. ... For additional information, you should refer to Policy Statement P-078 entitled " Meaning of the phrase delivered or made available in (or outside) Canada to the recipient ". 2. ... Nanner        GAD #: 1619(REG) G. Ryhorchuk ...

According to the […] (Pension Plan Rules): • […] there shall be paid from the Fund: (i) the costs of administering the Plan and the Fund, and (ii) all pensions, lump sums, refunds and interest to be paid under the Plan. • […] outlines certain fees and expenses that shall be paid by the Company to the extent they relate to the […] provisions […]. • […], the Company shall pay into the Fund such amounts […], to enable the Fund to provide for payment of all pensions, lump sums, refunds, interest and administrative costs required to be paid under the Plan. 3. ... This amount was comprised of $[…] of GST and $[…] of PVAT. The pension rebate claimed amounted to $[…]. 5. […]. 6. ... The December 2010 fiscal year is not the first fiscal year of the Trust. 9. […]. ...

Shares") at a price of $[...] per share (max. [#] shares / $[...]). ... Management Fee and a [...] Service Fee [...]. The Service Fee is equal to [...]% [...] of the [...] Shares (subject to certain adjustments) held [...] by the Clients [...] [...] the Agreement and the Prospectus both state that the Investment Manager is required to pay to the Dealers a service fee [...] based on the number of [...] ...

En bref, elle comprend non seulement une " entreprise " ou " un projet à risques... de caractère commercial " " sauf dans la mesure où l'entreprise comporte la réalisation par la personne de fournitures exonérées " mais aussi "... la réalisation de fournitures, sauf des fournitures exonérées, d'immeubles appartenant à la personne, y compris les actes qu'elle accomplit dans le cadre ou à l'occasion des fournitures.) ne peut pas s'inscrire à la TPS/TVH. ... -à-d. un " constructeur-locateur ") (Le terme " constructeur " est défini au paragraphe 123(1). ... Le remboursement est égal au moindre de la teneur en taxe (L'expression " teneur en taxe " est définie au paragraphe 123(1). ...

27 February 1996 GST/HST Interpretation 11640-3[14]- Supply of Drivers' Services Unedited CRA Tags ETA 133; ETA 142; ETA 165; ETA 169; ETA Sch VI, Part V, 7; ETA Sch VI, Part VII, 6                                                                         Telephone #: (613) 954-8585                                                                         Fax #: (613) 990-1233                                                                         File #: 11640-3                                                                         s. 133, 142, 165, 169 Sch. ... I will now discuss the tax status of the supplies: •   When the drivers' services are supplied to resident freight transportation companies, the services are subject to the GST at 7% under the provisions of subsection 165(1) of the Act. ... Nanner        GAD #: 1614(REG) G. Ryhorchuk E. Vermes ...

The association you are inquiring about has the following membership rights and obligations: •   the membership is to a non-resident professional association; •   the membership dues are XXXXX per year; •   members receive the following benefits: •   professional networking; •   professional recognition; •   leadership opportunities; •   competitions and awards; •   opportunity to be published; •   continuing education; •   on-line education; •   access to experts in the field; •   job referral service; •   access to medical insurance and a credit card program; •   internet discussion forums; and •   voting rights. •   members are entitled to receive the following publications, at no charge: •   a catalogue of publications in their professional field; •   a monthly newsletter; •   a monthly magazine; and •   a quarterly journal. •   non-members could receive both the catalogue and the newsletter for free while they would have to pay $XXXXX per issue in respect of the magazine and the journal; •   magazine cost per year is therefore $XXXXX •   journal cost per year is therefore $XXXXX •   total cost per year: $XXXXX •   members are entitled to a discount on seminars and educational programs at an average savings of approximately $XXXXX Your have asked two specific questions. ... Interpretation Given Question 1: Revenue Canada Policy Number P-077R " Single and Multiple Supplies " provides factors and guidelines to review which the Department will consider in determining whether a supply will be considered to be a single supply or multiple supplies. ... Question 2: We refer you to the GST/HST Guide titled " Information For Non-Resident Suppliers of Publications " (a copy of which is attached). ...

These additional sponsorship features include: a) Joint Venture Team (Cash sponsorship of XXXXX or more): •   full page advertisement in the final program; •   opportunity to XXXXX •   opportunity to make a brief presentation to conference delegates affirming sponsor's support of the XXXXX industry; •   five complimentary conference registrations, with an additional complimentary registration for each additional XXXXX •   opportunity to add XXXXX to the sponsor's Internet home page; •   opportunity to incorporate XXXXX into the sponsor's print materials; •   recognition in all media releases; •   all benefits of the XXXXX level (see below). b) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite (one night); •   complimentary exhibit booth XXXXX value); •   four complimentary registrations XXXXX value); •   early and final registration lists of delegates and exhibitors. c) XXXXX (Cash sponsorship of XXXXX •   complimentary hospitality suite XXXXX •   complimentary exhibit booth XXXXX value); •   three complimentary registrations XXXXX value); •   early and final registration list of delegates and exhibitors. d) XXXXX (Cash sponsorship of XXXXX •   complimentary exhibit booth XXXXX value); •   two complimentary registrations XXXXX value). e) XXXXX (Cash sponsorship of XXXXX •   one complimentary registration XXXXX value). 5. ... Furthermore, it is our ruling that the sponsorship payments are in respect of promotional supplies to which section 135 (see Explanation below) of the Excise Tax Act ("ETA") applies, and in respect of the following taxable supplies: •   conference registrations; •   exhibit booth; and •   hospitality suite. The following promotional supplies made by XXXXX in exchange for the sponsorships fall within the parameters of section 135 of the ETA: •   recognition of sponsor on conference signage; •   recognition of sponsor in promotional brochures; •   sponsor's profile included in the final conference program; •   sponsor's receipt of a full-page advertisement in the conference program; •   recognition of sponsor in conference media releases; •   sponsor's right to include information and promotional items in registration kits; •   sponsor right to use of XXXXX logo on sponsor's Internet home page; •   sponsor right to use of XXXXX logo in sponsor's print materials; •   sponsor's right to express registration and conference check-in (incidental); •   early and final registration lists of delegates and exhibitors (incidental), •   sponsor's right to chair sessions; and •   sponsor's right to make a presentation to delegates.   ...

The claim was made up of the contract price and other additional charges for additional work, expenses, impacted costs and loss of productivity as follows: •   contract price XXXXX •   approved change orders $XXXXX •   additional change orders $XXXXX •   room & board $XXXXX •   additional work $XXXXX •   more additional work $XXXXX •   drawing revision $XXXXX •   misc. items $XXXXX •   disputed work $XXXXX •   time sheet- field work $XXXXX •   disputed work $XXXXX •   impacted costs $XXXXX •   head office costs $XXXXX •   loss of productivity $XXXXX Total $XXXXX Less payment (prior to May 1, 1991) $XXXXX Subtotal $ XXXXX GST $ XXXXX Total amount claimed as owing $ XXXXX including GST XXXXX counter-claimed against XXXXX for the sum of XXXXX but later reduced the amount to $XXXXX[.] ... You advised us that: •   the various amounts claimed by XXXXX were invoiced to XXXXX and booked by XXXXX as receivables prior to XXXXX- after the judgment, XXXXX received the net amount approved by the Court from XXXXX plus the related GST; •   XXXXX called up your office to see if the amount should be subject to GST; •   XXXXX indicated the contract had hundreds of pages, and would not be convenient to forward it to you for review. ... Phil Tang Specialty Tax Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate ...

STATEMENT OF FACTS Based on the information you provided, our understanding of the facts is as follows: Parties involved: * […] (Vendor) – sets up ATM bank machines (i.e., sells equipment & related software licences), * […]([…][X]) – assignor and subsequently lessee, * […] (Lessor), a non-depository short term credit institution that provides primary equipment financing through leases – assignee and subsequent lessor All parties are registered for GST. Facts: * [X] enters into an “Acquisition Agreement” to acquire equipment & software licenses from the Vendor. * [X]’s acquisition of the equipment does not include the purchase of any software which is licensed to [X] by the Vendor. ... It is not clear how this particular taxable supply was accounted for, since the full Equipment Lease Agreement [#] was not submitted […]. […] […] [ABC] has referred to section 165 of the ETA to say that “every recipient of a taxable supply made in Canada” shall pay GST/HST based on the “value of the consideration for the supply”. ...

BACKGROUND INFORMATION From [...], we understand that the relevant facts are as follows: 1. [...] (the General Partner) is the sole general partner of [...] ([...] [Limited Partnership A]). ... The General Partner is also the general partner for two other limited partnerships: [...] ([...] ...