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GST/HST Interpretation

16 March 2021 GST/HST Interpretation 199648 - Location de véhicules routiers à des Indiens

. / 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. ... Dans ce contexte, le client Indien pourrait bénéficier de son exemption. […] Nous sommes d’accord avec votre conclusion. ... […] Vous êtes d’avis que la taxe payée par le client Indien ne constitue pas une taxe payée par erreur au moment où le concessionnaire la perçoit. ...
GST/HST Interpretation

26 October 1995 GST/HST Interpretation 1995-10-26 - Application of the GST to the Supply of Legal and Professional Services

Furthermore, XXXXX is requesting authorization to grant an adjustment in the amount of $ XXXXX to XXXXX for legal services it rendered from march 1993 to November 1, 1993. ... The following is my rationale: •   Under Item 12(a), the civil litigation services appear to be in respect of alleged defaults pursuant to the long-term supply contracts entered into between XXXXX and the Producers (XXXXX gas producers). •   XXXXX a wholly owned subsidiary of XXXXX purchases natural gas (tangible personal property) from the Producers while XXXXX in turn, also a wholly owned subsidiary of XXXXX carries over its pipeline system to XXXXX natural gas it purchases from XXXXX •   The Producers sought a block action against XXXXX and its related companies for breach of contracts (i.e., to purchase from the Producers minimum annual quantities of natural gas over extended periods corresponding to the life of the Producers' gas fields). ... The above supply is also not in respect of tangible personal property that is situated in Canada at the time the service is performed. •   The shares owned by XXXXX and XXXXX both unregistered non-residents at the time, were those of XXXXX and XXXXX respectively; XXXXX was a wholly-owned subsidiary of XXXXX and XXXXX owned a XXXXX % share of XXXXX •   It appears that the supply of the services are in respect of the proposed sale of the shares and not in respect to the shares themselves. ...
GST/HST Interpretation

20 December 1996 GST/HST Interpretation N/A - Representative/Clearance Certificate

20 December 1996 GST/HST Interpretation N/A- Representative/Clearance Certificate Unedited CRA Tags ETA 270(1); ETA 270(3) XXXXX December 20, 1996 Subject: Ss. 270(1) & (3) ETA- Representative/Clearance Certificate Dear XXXXX We are replying to your facsimile message of November 25, 1996 in which you asked for assistance in determining whether a lawyer acting for a client, i.e., vendor, within the context of a real estate transaction would be a "representative who is administering,... controlling or otherwise dealing with any property, business, commercial activity or estate of a registrant... ...
GST/HST Interpretation

10 January 2018 GST/HST Interpretation 163984 - Eligibility for corporation to claim full ITCs

. / 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. ... FACTS/BACKGROUND: Based on the information […] provided, […], we understand that […](the Manager) requested the CRA to consider the wash transaction provisions with respect to asset management services it provides to the Corporation. ... The Agreement includes the following provisions: […] When requested by the Corporation, the Manager is required to provide services regarding the Assets [of the Corporation], […] For performing the services regarding the Assets, the Agreement provides that the Manager is to be paid an amount for each fiscal year […]. ...
GST/HST Interpretation

14 July 2004 GST/HST Interpretation 53036 - Application of the GST/HST to potential out-of-court settlement

XXXXX XXXXX XXXXX XXXXX You also provided the following documents: •   XXXXX, Statement of Housing Program Expenditures for the Year Ended XXXXX. •   XXXXX, Non-Consolidated Financial Statements for the Year Ended XXXXX. •   XXXXX, Statement of Housing Program Expenditures, XXXXX. •   XXXXX, Non-Consolidated Financial Statements, XXXXX. ... The Financial Statements identify 'housing ' as a program area of responsibility. ... Leclaire Municipalities and Health Care Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2004/06/03 RITS 33953 Tax Application of Road Construction Services Provided by the City of XXXXX to the Province XXXXX ...
GST/HST Interpretation

8 February 2000 GST/HST Interpretation 13547 - Registered Charity Voucher Ruling Request

Your E-mail and subsequent telephone conversations provided the following facts, based on information received from the correspondent: •   The Charity is currently registered for the HST. •   The Charity is a registered charity for purposes of the Income Tax Act of Canada, and is therefore required to report its net tax in accordance with section 225.1 of the Excise Tax Act (the Act). •   Each year the Charity organizes a XXXXX held in City X in a participating province which includes participants from around the world. The participants are unpaid volunteers. •   The Charity provides each participant with meal "vouchers", which can be used at various restaurants. •   The vouchers are printed by a sponsor of the Charity. Separate vouchers for lunch and dinner in different denominations are printed. •   The value of the vouchers is XXXXX for lunch and dinner respectively. •   The vouchers are coded in such a manner that the Charity is able to determine how many vouchers have been redeemed by various branches of the XXXXX. •   All participants must sign for all vouchers issued to them. •   The participant will use the voucher as partial consideration for a meal at a participating restaurant. ...
GST/HST Interpretation

5 September 2002 GST/HST Interpretation 40484 - Drawbacks and Refunds

Subsection 215.1(1) of the Act permits a rebate of Division III tax on returned goods, which meet the following conditions: •   person paid Division III tax upon importation of the goods •   person acquired the goods on consignment, approval, sale-or-return basis or other similar terms •   goods must be exported by the person for the purpose of returning them to the supplier •   goods must not be used or consumed other than on a trial basis prior to exportation •   the goods must not be damaged after their release and before they are exported •   the goods must be exported within 60 days after their release, and •   the person must apply within 2 years after the day the tax was paid, for a rebate of the tax on a prescribed form containing prescribed information. ... Section 263 of the Act provides that a person is not entitled to a rebate of an amount under various sections, including subsection 215.1(1), to the extent that it can reasonably be regarded that: •   the amount has previously been rebated, refunded or remitted to the person; •   the person has claimed or is entitled to claim an input tax credit (ITC) in respect of the amount; •   the person has obtained or is entitled to obtain a rebate, refund or remission of the amount; or •   a credit note has been received by the person or a debit note has been issued by the person, for an adjustment, refund or credit that includes the amount. ... NCS Subject Code(s): I-11645-5 c.c.: Tammy Myers, Team Leader, Domestic Rebates Section, Business Returns & Payments Processing Directorate, Canada Post Place, 750 Heron Road c.c.: Patrick McKinnon, Manager, Border Issues Unit c.c.: Brenda Ginsberg, Prepayment Programs, Small and Medium Enterprises Division, Place de Ville, Tower B ...
GST/HST Interpretation

18 April 1996 GST/HST Interpretation 1996-04-18 - Self Assessment of Residential Pty

18 April 1996 GST/HST Interpretation 1996-04-18- Self Assessment of Residential Pty Unedited CRA Tags ETA 207 E-MAIL MEMOR1653 XXXXX XXXXX XXXXX FROM: Mike Place HQ Rulings and Interpretations DATE: April 18, 1996 Subject: Self Assessment of Residential Pty / s. 207 We have the following comments in reply to your query of March 11, 1996. ...
GST/HST Interpretation

19 November 2003 GST/HST Interpretation 45736 - GST Voluntary Disclosures - "No Name Disclosure"

. / Veuillez prendre note que ces documents, bien qu'exacts au moment émis, peuvent ne pas représenter la position actuelle de l'Agence. ... In essence, they convert a forward contractual obligation into a futures obligation. 1 (Futures & Options, Franklin R. ...
GST/HST Interpretation

9 June 2003 GST/HST Interpretation 43523 - Assessment of GST on Purchasers Under Paragraph 296(1)(b) of the Excise Tax Act (the "ETA")

This is reinforced in Coopers & Lybrand Ltd. v Bank of Montreal [1993] G.S.T.C. 36 whereby Judge Orsborn at paragraph 38 stated in part; "The assessment... is issued by the Minister of National Revenue (the Minister) pursuant to subsection 296(1) of the Act. ...

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