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Administrative Policy summary
GST/HST Memorandum 4.5.1 “Exports - Determining Residence Status” January 1998 -- summary under Section 7
. … Responsibility of resident supplier to obtain certificate or other residency evidence Responsibility of registrant suppliers 16. ...
Administrative Policy summary
GST/HST Memorandum 3.1, “Liability for Tax” (August 1999) -- summary under Real Property
. … Intangible personal property 58. Intangible personal property includes contractual rights, options, shares in the common stock of a corporation, the right to recover a debt, intellectual property (patents, trade-marks, trade-names), and rights in relation to goods that are not in possession and other rights which may be enforced by the courts, but does not include money. ...
Administrative Policy summary
5 May 2021 IFA Roundtable, Q.2 -- summary under Article 7(1)
. … [T]he CRA will continue to contemplate the application of the GAAR to transactions undertaken primarily to secure a tax benefit afforded by a tax treaty. ...
Administrative Policy summary
GST29 Educational Services - Election and Revocation of the Election to Make Certain Supplies Taxable -- summary under Section 6
GST29 Educational Services- Election and Revocation of the Election to Make Certain Supplies Taxable-- summary under Section 6 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part III- Section 6 Description of election under s. 6 (Type 1) Type 1 Election (section 6 of Part III of Schedule V to the Excise Tax Act) – Fill out Part 2 to elect to have GST/HST apply to your supplies of instructing individuals in, providing certificates for, or administering examinations for, courses that lead to, maintain, or upgrade a professional or trade accreditation or designation recognized by a regulatory body. ...
Administrative Policy summary
GST/HST Memorandum 17-12 [17.12] "Input Tax Credit Allocation Methods for Financial Institutions for Purposes of Section 141.02" 23 July 2021 -- summary under Subsection 141.01(2)
. … 11. Although the procurative extent (intended use) of a business input is based on the purpose for which the particular business input was acquired at the time it was acquired, the actual use of the business input may help clarify what the financial institution’s intention was at the time the property or service was acquired. ...
Administrative Policy summary
25 March 2021 CBA Commodity Taxes Roundtable, Q.2 -- summary under Subsection 191(3)
When asked whether “neither (a) the original CRA Real Estate Appraiser nor (b) any appraiser within the same group/office of the initial CRA appraiser will be involved or provide input respecting the objection or appeal and that if CRA’s Appeal Division requires input in respect of the GST-registrant’s Objection or Appeal, such advice will be provided by a wholly independent CRA appraiser from a different CRA Real Estate Appraisal Group/Office, without contact with … the initial CRA appraiser,” CRA responded only by indicating that its appraisers were required under their professional standards to be impartial and unbiased. ...
Administrative Policy summary
Underused Housing Tax Notice UHTN15, Questions and Answers About the Underused Housing Tax, 17 April 2023 -- summary under Subsection 7(1)
Need claim only 1 exemption (paras. 3.2, 3.3) When filing a return, an owner need only claim one out of a number of applicable exemptions – although, in light of s. 47(2), the exemptions in s. 6(7)(c) to (f) may be considered less desirable. ...
Administrative Policy summary
7 April 2022 CBA Roundtable, Q.14 -- summary under Paragraph 2(a)
. … [P]roperty and services that could be eligible for zero-rating under this provision include: fuel and other supplies; railway junction and switching charges, pilotage services, aircraft landing fees; railway right-of-way charges, and warehouse fees; stevedoring services; spare parts, repair, and maintenance services; and air navigation services. ...
Administrative Policy summary
23 December 2016 Comfort Letter re s. 95(2)(b) base erosion rule -- summary under Subclause 95(2)(b)(i)(B)(I)
Holdco was formed to acquire shares of Opco, carrying on an active business, and Manager provides asset management and investment advisory services respecting Opco for a fee – which is paid by Holdco, rather than Opco, because Holdco is not the sole shareholder of Opco. ...
Administrative Policy summary
23 March 2017 CBA Commodity Taxes Roundtable, Q.20 -- summary under Section 2
. … If Mr. X is not a builder in his own right (for example, at the time of entering into the agreement of purchase and sale, he intended to acquire the house for his personal use), the sale of that interest would generally be exempt under section 2 of Part I of Schedule V to the ETA. ...