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GST/HST Interpretation
12 August 2005 GST/HST Interpretation 56852 - Eligibility for input tax credit for GST paid on purchase of a truck
The following information has been provided in your letters, from the web-sites of XXXXX and during our telephone conversations XXXXX: • XXXXX. • The XXXXX receives funding from the XXXXX. • The office of the XXXXX is not located on a reserve. • XXXXX. • The members of the XXXXX are elected and are responsible for their operating budget XXXXX. • For the year XXXXX a motion was passed by the XXXXX designating the office of XXXXX as the finance and administration unit in charge of budgets, accounting, supporting document retention, monthly financial statements, etc. • The XXXXX is incorporated under the Laws of Ontario as a corporation XXXXX. • The XXXXX is overseen by a Board of Directors representing the XXXXX. • The objective of the XXXXX. • The office of the XXXXX is not located on a reserve. XXXXX. • The XXXXX elects the directors of the XXXXX from the members of the XXXXX. ... Chesterman Aboriginal Affairs Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2005/06/30 — RITS 57840 — Supplies to Partnership ...
GST/HST Interpretation
20 August 2012 GST/HST Interpretation 140855r - Carrying on business in Canada
USco is in the business of providing […] information to its customers. ... USco purchases some […] information from […], Canco. 6. Canco does not have contact with USco’s customers and is not otherwise involved in the supplies made by USco to its Canadian customers. 7. ... As explained in GST/HST Policy Statement P-051R2, Carrying on business in Canada, 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. ...
GST/HST Interpretation
25 February 2005 GST/HST Interpretation 51031 - GST on the supply of a condominium unit
The statement of account is as follows: Income from sale: $ XXXXX Expenses from Dispersal: Estate Dispersal Services XXXXX $ XXXXX Estate Fees XXXXX $ XXXXX Disposal Fees $ XXXXX Carpet Cleaning $ XXXXX Casual Labour $ XXXXX Bank Fees on Credit Cards $ XXXXX Hardware Supplies $ XXXXX GST XXXXX $ XXXXX • You also provided a sample covering letter addressed to the Owner that refers to attachments to the letter: the statement of account, the cheque payable to the Owner, XXXXX and a letter of appreciation from a local charity. • A sample follow-up letter describing a job was not provided. 5. ... For further details and examples of agency relationships, we are enclosing GST/HST Info Sheet GI-009 entitled " Consigned Goods ". ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2005/02/08 — RITS 52141 — Stock Options for Independent Contractors ...
GST/HST Interpretation
7 August 2003 GST/HST Interpretation 41502 - ITC Implications on ATM Operators
In their letter, XXXXX provided the following information: • XXXXX choose their own locations, which appear profitable based on traffic flow and availability of ABMs in the surrounding area. • XXXXX negotiated an agreement with the location owner to allow for the installation of an ABM for which they pay a portion of the applicable surcharge amount. • The surcharge amount varies from XXXXX per withdrawal based on the affordability and need of customers using the ABM. • XXXXX. fills the ABM with their own cash from their business account. ... In XXXXX opinion, they should be allowed to claim ITCs on the purchase of the equipment to get started in its XXXXX venture because the ABM operations business was started with the following objectives in mind: • To purchase and install ABMs at potentially profitable locations, establish the business with a view to improve the transaction volume and then find suitable customers who would buy their ABMs along with an established location and pay a certain price which would provide a sizeable profit. • XXXXX[.] • XXXXX[.] ... In a letter XXXXX provided to the CCRA, XXXXX confirmed having sold XXXXX ABMs, which according to the documentation we have were placed in the following retail locations: • XXXXX • XXXXX • XXXXX • XXXXX As for the current status of the ABMs, XXXXX wrote a letter to the CCRA stating that the ABM at XXXXX and the other XXXXX locations were being offered for sale to potential buyers. ...
GST/HST Interpretation
3 May 2022 GST/HST Interpretation 197305 - Véhicule utilisé pour fournir des services de covoiturage commerciaux
Une « voiture de tourisme » est défini au paragraphe 123(1) comme une voiture de tourisme ou une voiture de tourisme zéro émission, au sens du paragraphe 248(1) de la [LIR]. Selon ce paragraphe, une « voiture de tourisme » désigne généralement une « automobile » acquise après le 17 juin 1987. ... Bien que la prestation de services de covoiturage commerciaux soit une « entreprise de taxi » aux fins de la TPS/TVH, il n'était pas clair si un véhicule utilisé pour fournir de tels services était considéré comme un « taxi » dans le contexte de la définition d'automobile dans la LIR. ...
GST/HST Interpretation
29 May 1997 GST/HST Interpretation HQR0000360 - L'application de l'alinéa 1c) de la partie V de l'annexe VI de la Loi sur la taxe d'accise (la Loi) aux différents procédés effectués par les commerçants de peaux d'animaux.
VI, partie V, 1(c) Téléphone no: (613) 954-8585 Télécopieur no: (613) 990-1233 HQR0000360 Alinéa 1c), partie V, annexe VI Fichier #: 11640-4(dc) XXXXX le 29 mai 1997 XXXXX Cher Monsieur, La présente fait suite à la demande de renseignements présentée par XXXXX de XXXXX le 15 octobre 1996, par rapport à la position de notre Ministère concernant l'application de l'alinéa 1c) de la partie V de l'annexe VI de la Loi sur la taxe d'accise (la Loi) aux différents procédés effectués par les commerçants de peaux d'animaux. ...
GST/HST Interpretation
17 January 2011 GST/HST Interpretation 125334 - Application of the GST/HST to certain services provided by automobile dealers
The employees of the dealership perform the following activities: • obtaining the credit information from the customer; • completing a loan application form; • explaining to the customer the different loan terms and interest rates available; • helping the customer select the type of loan which best suits the customer's needs; • determining the interest rate and payment stream; and • screening and verifying the loan application, making a recommendation on acceptance or rejection of the application and forwarding it for final approval to the financial institution which will grant the credit. ... In offering a loan, the automobile dealer must negotiate a number of different financing variables with the customer, such as: • amount to be financed; • term; • down payment; • security deposit; • addition/reduction of accessories or ancillary products (e.g. supplementary warranties); • a co-buyer to support the credit risk; and • co-guarantor to support the credit risk. • As the automobile dealer negotiates the terms and conditions of a loan with a customer, the automobile dealer is always cognisant of the quality criteria required by its various potential assignees. • If an automobile dealer hopes to eventually assign a loan to an assignee, the automobile dealer will generally submit the loan application to the assignee in advance. ... Among the most common examples, the potential assignee can choose to pay: • a fixed amount for its purchase of the loan; • an amount calculated on a percentage of the sum financed; • nothing- example where the auto manufacturer decides to subsidize the rate of interest paid by the customer; • at a premium or discount to the face amount based on the assignee using a different interest rate target than the loan rate. • At any particular time, an automobile dealer can find out from different potential assignees what they may be willing to offer in terms of accepting assignment of a loan. ...
GST/HST Interpretation
30 May 2011 GST/HST Interpretation 85885 - GST/HST treatment of trailer park site rental
The Park is located [...] in the municipality of [...] [Participating Province X]. ... It has a total of [...] sites. [...] of the sites are for transient campers. ... For example, the unit on Lot [...] is described as [...]. Sale prices for these units range from $[...] to $[...]. ...
GST/HST Interpretation
4 April 2011 GST/HST Interpretation 92799 - GST/HST treatment of sale of shares and associated rights to use land
[Company B] and [...] [Company C] formed a joint venture called [...] ... Such rights, limitations and obligations are as set out in the [...], which includes Schedule [...], [...] ... You paid $[...] at the time of entering the Purchase and Sale Agreement and gave the Developer [...] post-dated cheques, each for $[...], and dated for the first day of each month beginning [mm/dd/yyyy] (i.e., the cheques totalled $[...]). ...
GST/HST Interpretation
17 February 1997 GST/HST Interpretation HQR0000212 - Clarification As to What Constitutes a "Music Lesson" and What Constitutes a Child-care Service (Rather than a Recreational Service) Under the Excise Tax Act (ETA)
XXXXX provides the following programs: (A) XXXXX • XXXXX[;] • provides music appreciation and experience for children XXXXX[;] • class meets one time per week XXXXX[.] (B) XXXXX • provides an environment for children XXXXX in which emotional, physical, intellectual and creative experiences are offered through a combination of a play school and music program; • XXXXX[;] • XXXXX[.] ... Music lessons include lessons that develop skills in: • musical performance (involving the use of the human voice or musical instruments); • conducting an orchestra; or • musical composition. ...