Search - 报销 发票日期 消费日期不一致

GST/HST Rulings Directorate 5th floor, Tower A, Place de Ville 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 246958 [Dear Client:] SUBJECT: [GST/HST interpretation] Zero-rated Supplies of Financial Services and Eligibility for Input Tax Credits This […] is in response to your […][correspondence] of [mm/dd/yyyy], […] concerning the eligibility for input tax credits (“ITCs”) of […] (the “Investor”) in respect of its investment in a non-resident partnership. […]. ... The Investor became registered for GST/HST purposes […] effective [mm/dd/yyyy]. 3. ... The initial Capital Contribution of each Partner was credited to the capital account of each Partner, as set forth on Schedule […] of the LPA, which lists the Investor as holding a […]% Interest in the Non-resident Partnership, […] LP as holding […]% Interest and […] GP as holding 0% Interest. 11. […][quote from agreement] 12. […][quote from agreement] 13. ...

La TVH s’applique dans les provinces participantes aux taux suivants: 13 % en Ontario et 15 % au Nouveau-Brunswick, à Terre-Neuve-et-Labrador, en Nouvelle-Écosse, et à l’Île-du-Prince-Édouard. ... Selon les renseignements fournis […] portant sur l’interprétations du terme « service de transport de passagers » pour l’application des mesures de détaxation prévue dans la Partie VII de l’Annexe VI. […] le moyen de transport n’est pas offert au public. ... Ces voyages génèrent des avantages imposables pour les employés et actionnaires. […]. ...

14 February 1996 GST/HST Interpretation 11650-1[5]- Eligible Capital Property and Capital Property Unedited CRA Tags ETA 123(1) capital property; ETA 200                                                                         11650-1 (ms)                                                                         Sections 123 & 200 XXXXX February 14, 1996 Dear XXXXX Thank you for the memorandum dated December 21, 1994, from XXXXX, in which you request a GST interpretation of certain issues relating to eligible capital property and capital property in reference to the purchase of an "insurance book'' as part of the purchase of assets of a company in receivership. ... Jones Director General Applications Division GST Rulings and Interpretations Doc. #: 1056 (REG) c.c.:      John Sitka M. ...

. •   The Contract outlines the rights and responsibilities of the two parties in respect of the sale of books to third parties in Canada. •   Based on information provided by XXXXX XXXXX concluded their offer and acceptance of this Contract in the XXXXX •   XXXXX •   XXXXX B. ... CANADA • Pursuant to clause 11 of the Contract XXXXX must provide statements to XXXXX outlining the books it has removed from XXXXX inventory. ... Although the profits in relation to the Contract arise in Canada, the following facts lead us to conclude that the remaining ties are not strong enough to support a position that XXXXX  is carrying on business in Canada: •   the books are published in the U.S.; •   XXXXX  pays for the books in U.S. funds; •   the funds are received by XXXXX  and deposited into its bank accounts in the U.S.; •   XXXXX does not have an office or branch in Canada; •   XXXXX  does not have any employees or agents acting on its behalf in Canada; •   XXXXX  is not listed on directories in Canada; •   sales to final consumers are made by XXXXX name as vendor on sales invoices; and •   revenues in relation to the Contract are accounted for by XXXXX as sales revenue. ...

1 March 1996 GST/HST Interpretation 11755-22- GST Interpretation Section 232 of the Excise Tax Act Unedited CRA Tags ETA 232                                                                         File #: 11755-22(km) XXXXX March 1996 Subject: GST Interpretation Section 232 of the Excise Tax Act Dear Mr. ... Such a credit or debit note must contain the following information, •   a statement or other indication that the document in question is a credit or debit note; •   the dealer's name and GST registration number; •   the customer's name (or the name of the customer's duly authorized agent or representative[)]; •   the date on which the credit or debit note is issued; •   a statement specifying whether the credit or debit note relates to an adjustment, a credit or a refund; •   the date on the sales agreement or invoice issued to the customer when the vehicle was sold; •   description of the vehicle (e.g. make, model, year, VIN #), and •   the amount of the reduction and the amount of GST in respect of that reduction (if the sales agreement or invoice did not show the purchase price and GST separately, then the credit or debit note should show a GST included amount along with a statement that the amount includes GST) Where a particular dealer has adjusted, refunded or credited an amount of GST to a customer according to the above rules, the dealer may, pursuant to paragraph 232(3)(b) of the ETA, deduct that amount of GST in determining their net tax for the reporting period in which the credit note is issued or the debit note is received. ...

. / 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. To: [Addressee] From: Susan Kissner Insurance and ITC Allocation Unit Financial Services and Real Property Division Excise and GST/HST Rulings Directorate Case Number: 170944 SUBJECT: GST/HST INTERPRETATION Application of GST/HST […][to the Product Replacement Program] and […][the Company] The following are our comments […] concerning the operations of […]([…][the Company]) and a […][product replacement program] provided to […][customers] of […] and […]([…][X]). We apologize for the delay in responding to your request. […], the following is our understanding of the information that was provided: […] [INTERPRETATION REQUESTED] […] [X] and [the Company] have made an election under subsection 177(1.1) of the ETA. ...

Other relative terms of the agreement are as follows: •   the member has right of occupancy until the member dies, or until the member demands and receives repayment of the loan, or until the society terminates occupancy based on the member's breach of the terms (housing charges, regulations, rules of conduct etc set out in the agreement) •   the agreement does not refer to the terms "lease, licence or similar arrangement" Members' Covenants •   that occupancy "does not create any interest in Land, legal or equitable and in particular, does not create a charge against either the Unit or the Common Property in favour of the Member." •   to pay monthly "housing charges" to the Society which is set annually by the Society's Board of Directors •   to use the unit exclusively as a private residence for a member who is a senior citizen... •   that the right to use the unit and to occupy the unit is personal to the member, and that such right cannot be assigned... cannot be leased, rented or otherwise occupied by any party for gain...cannot be occupied by any party other than the member without express written consent of the Society... •   Other covenants: to abide by "good neighbour" provisions, not to make alterations to the unit without consent of the Board; to keep the interior in good condition and repair •   to permit the Society or its agents entry at reasonable times on notice for the purpose of inspecting, repairing etc. •   not to assign any interest of the member in this agreement except with the prior written consent of the Board •   not to sublet the unit or any portion thereof except with the prior written consent of the Board Society's Covenants •   that the member may quietly have, hold and enjoy the unit pay utilities •   maintain common areas, repair foundations & exteriors of the units ensure fees levied equally disbursed properly on account of services enforce rules & regulations Lease, Licence or Similar Arrangement The submission from XXXXX is that the self supply rules of subpara 191(3)(b)(i) do not apply since the occupancy at issue is not a "lease, licence or similar arrangement. ... At law, the categories of estates and other rights to real property include •   freeholds (fee simple, fee tail, life estates), •   leaseholds, and •   rights that are not estates in property (easements, licences, profits à prendre, restrictive covenants and particular rights such as those pertaining to water, minerals, air space etc.). ...

28 October 1996 GST/HST Interpretation 11585-32[1]- Input Tax Credits Unedited CRA Tags ETA 156; ETA 165 XXXXX File: 11585-32 RITS: HQR0000280                                                                         October 28, 1996 Attn: XXXXX Dear Sir: This is in reply to your letter of September 12, 1996 wherein you indicate that "Revenue Canada will not allow one company in a multi-employer pension plan to claim the GST input tax credits (ITCs) in respect of eligible 'Employer Expenses' incurred by the pension plan, even where the group consists of related companies", and that this does not seem fair "particularly where all of the employers are part of a related group that are otherwise allowed to nil elect under section 156 of the Excise Tax Act (the "Act") with respect to transactions among themselves". ... Tang Policy Officer Financial Institutions and Real Property Division GST Rulings & Interpretations Directorate Telephone #: (613) 954-8585 Fax #: (613) 990-1233 ...

The supplier did not respond to your request. •   By letter XXXXX, the XXXXX confirmed that the supplier has ceased operations. ... This is provided that the following conditions have been met: •   the contributions were placed in a trust fund pursuant to provincial legislation or the terms of the contract itself; •   the funeral home that was the original party to the agreement, has, since its registration for the GST/HST, accounted for the HST in respect of the contributions at the time the arrangements were entered into; •   the HST has not been refunded, credited, or rebated to the purchaser; and •   the funeral home has not subsequently claimed an input tax credit or an adjustment for that HST in its net tax. ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2004/08/19 — RITS 53344 — Tax Status of Services Provided by a Sales Representative ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Because the Centre provides chronic care to individuals that stay overnight at the Facility, documentary evidence required to establish whether it qualifies for an 83% PSB rebate as a facility operator includes: • Funding agreements between the Centre, the Ministry; • Service Agreement with the Ministry; • Financial Statements of the Centre; • Reports prepared by the Ministry in respect of the operations of the Centre; • A sample of agreements entered by the Centre with residents at the Facility identifying the specific health care services that the Centre provides to residents (sanitized); • Sample care plans of residents at the Facility (sanitized); • Records of the number of physician visits to residents at the Facility; • Service agreements entered into by the Centre with physicians and any other documentation respecting physician involvement in the care provided to residents at the Facility. ... A physician involvement in an individual's care must be on a continual and ongoing basis and simply not on an "as-needed" basis; • Evidence that a registered nurse is at the Facility at all times; and • Evidence that the Centre provides more than 2.4 hours/day of therapeutic health care services to residents at the Facility.Regarding the Centre's other activities (e.g., respite care; XXXXX; XXXXX; clinics for families of residents' of the Facility), we would require evidence to support that any exempt supplies made in respect of these activities are part of a medically necessary process of health care for individuals for the purpose described in the definition of "facility supply" and that process is reasonably expected to take place under the active direction or supervision, or with the active involvement, of a physician. ...