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GST/HST Ruling

4 May 2021 GST/HST Ruling 187251 - Application of the GST/HST to the supply of fruit and vegetable juice blends

The Company has introduced some new blends of juice beverages, namely, […] (the Products), […]. 3. ... The customized orders may contain up to [#] bottles. […] customers […] select the flavours they want included in their customized packs. 7. The juice packages sold to wholesalers […] [include # of the single serving] bottles and contain a mix of the Products predetermined and prepackaged by the manufacturer. 8. […] [We understand] that the cost of a custom order package is based on the price associated with each individual product selected by the customer. […]. ...
GST/HST Ruling

8 April 2011 GST/HST Ruling 129078 - Tax status of gravel from Mining Property

The Agreement has a term of [...] years, with an option to negotiate every [...] years from the start date of the contract, [mm/dd/yyyy]. 3. ... Articles [...] and [...] of the Agreement state that [Company A] shall pay [the non-resident] for all aggregate materials removed from the Mining Property at a rate the greater of $[...] per metric tonne (the Royalty), or monthly minimum of $[...] ... Annual minimum Royalty is $[...]. 8. Article [...] of the Agreement states that the rate per tonne can be negotiated every [...] years, but the price will not fall below $[...] per metric tonne. 9. ...
GST/HST Ruling

29 August 2011 GST/HST Ruling 82030 - GST/HST RULING - GST/HST treatment of seasonal site rental at trailer park

(the Park) and the pro-rated portion of the municipal taxes that [...] ... The Park is located at [...] in [...] [Community 1], in the municipality of [...], [...] ... The trailer was manufactured to your specifications at [...]. It measures [...]' x [...]' and is situated on site #[...]. ...
GST/HST Ruling

17 November 2016 GST/HST Ruling 152989r - Tournament Registration Fees

The Charity is a charitable organization that hosts […] tournaments […] [objective of the charity]. 2. The format is […] [listed elements that form a single supply of a right to participate in a tournament]. 3. […] [details of elements included in the supply]. 4. Each participant pays a registration fee of $[…] and […]. 5. […] [additional details of elements included in the supply]. 6. ...
GST/HST Ruling

29 January 2015 GST/HST Ruling 159222 - GST/HST on fees relating to a loan

You asked us to refer to the following documentation provided to us by […][ACo]: * Term Sheet dated [mm/dd/yyyy], between [ACo] and […][BCo]; * Assignment Agreement dated [mm/dd/yyyy], between [ACo], […][CCo], and [BCo]; and * Acknowledgement and Agreement dated [mm/dd/yyyy], addressed to [CCo] and signed by […] on behalf of [BCo]. STATEMENT OF FACTS Based on telephone conversations with […] of your office and the documentation provided, we understand that: 1. ... The Term Sheet set out terms and conditions that would be subject to the full scrutiny of a due diligence review that would include, but not necessarily be restricted to, considerations contemplated therein, as follows: * Borrower: [BCo] * Lender: [ACo] or any company [ACo] chooses to use * Loan Facility: a demand term loan in the amount of $[…] * Rate of Interest: […][the Bank] Daily Prime Interest Rate plus […]% per annum payable monthly in arrears. * Commitment Fee: $[…] plus HST is payable on the execution by [BCo] of the Lender’s Commitment Letter (which we understand to be the Term Sheet itself). * Closing Fee: [BCo] agrees to pay a fee equal to […]% of the maximum of the Loan Facility, which is earned at the time the Lender first advances the Loan Facility with payments being postponed until the earlier of the maturity date of the Loan Facility or payout of the Loan Facility. * Term: […] months, on demand. * Interest Rate Adjustment Date: [BCo] shall pay interest on the entire loan facility amounts monthly, in arrears, on the 30th day of each month. ...
GST/HST Ruling

17 December 2013 GST/HST Ruling 153989 - A "public college" pursuant to subsection 123(1) of the Excise Tax Act

. / 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. ... [Province X]. 2) The Regulations to the Letters Patent of [the Organization] include: i) [...] states that [the Organization] is a not-for-profit organization that is responsible for funding education and training that it offers; ii) [...] states that [the Organization] is recognized by the Government of [Province X] as an integral part of the post-secondary system of education in [Province X] as it offers quality training in French. iii) [...] lists [the Organization]'s objectives [...] to accomplish its mission, [the Organization] has the responsibility to: a) be self-financing. b) promote continuing education programs and general interest courses [...], training and development for the adult population of [Province X]. c) make available to adults of [Province X] continuing education programs and general interest courses, training and development. d) [...]. e) organize, administer and provide training programs focused on employment, community training and personal training, as well as continuing education programs and general interest courses. f) issue certificates specifying that the students have followed the required courses and completed all related requirements. g) work with other stakeholders in the field of education and adult learning in [Province X] and [...] for the delivery of adult education in the province. h) [...]. i) [...]. 3) [The Organization]: i) offers the following post-secondary programs leading to a certificate/diploma: bilingual administrative assistant, bilingual bookkeeper, early childhood education, human services intervention worker, resident care worker, practical nursing program, and welding, all of which require the student to have a high school diploma or equivalency as an entrance requirement; ii) offers French language training courses at various levels ([...]); iii) provides training to adults working towards obtaining their grade 12 equivalency or their grade 12 academic certificate through its various centres; iv) provides training to individuals who need to work towards writing their GED exam; and v) offers general interest courses, such as, First Aid, WHMIS, and introduction to computers. 4) [...]. 5) [...]. 6) [...] indicates that the Government (of [Province X]) recognizes [the Organization]'s services as an integral part of the post-secondary education system. 7) [...] states that the: Government (of [Province X]) wishes to recognize [the Organization] as a publicly funded educational institution. 8) [...] provides for the potential for a subsequent [...] at the expiration of the current one. ... The conditions that have been met by [the Organization] that qualifies it as a "public college" are: * it is operating a post-secondary college or post-secondary technical institute; * it receives funds from a government that are for the purpose of assisting [the Organization] with its ongoing provision of educational services to the general public; and * the primary purpose of [the Organization] is to provide programs of instruction in one or more fields of vocational, technical or general education. ...
GST/HST Ruling

29 November 2012 GST/HST Ruling 134267 - […][Music Programs for Children]

[Program B] and [Program C] are offered in […][sessions]. [#] different music classes are provided as part of each program […] 3. You provided descriptions for each of the [#] classes that make up the [Program B] and [Program C] Programs. […] 4. […], holds […][various degrees in music]. […] has over [#] years of experience teaching young students and is a certified teacher with […]. ... * Does the instructor use a recognized method of teaching music? * Does the program involve non-musical elements? ...
GST/HST Ruling

29 September 2020 GST/HST Ruling 175147 - Application of the GST/HST to supplies of services made by a determined municipality to a regional municipality

In addition to the above user fees, the Authority also derives funding through municipal levies and provincial grants. […] […] The Regional Municipality […] 8. The Regional Municipality […] (the “Region”) is an upper-tier municipality […]. ... The Agreement 10. […], the Authority and the Region entered into a Service Agreement (the “Agreement”) […]. ...
GST/HST Ruling

30 April 2004 GST/HST Ruling 51330 - XXXXX

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... XXXXX intends to temporarily import the following amusement rides for use at fairs and exhibitions across Canada: •   XXXXX •   XXXXX •   XXXXX 2. ... Yours truly, John Sitka Director General Operations and Border Issues Division Excise and GST/HST Rulings Directorate Policy and Planning Branch 2004/04/27 RITS 51331 Temporary Importation of Amusement Rides ...
GST/HST Ruling

4 July 2024 GST/HST Ruling 207387 - Delivery services provided through […][the Platform]

The invoice number is […]. The description on the invoice is for a delivery service and the amount charged was $[…]. 6. ... The description on the invoice is for a delivery service and the amount charged was $[…] plus GST/HST $[…]. ... RULING GIVEN Based on the facts set out above, we rule that: [...], you are making a taxable supply of a delivery service subject to GST/HST at the applicable rate based on the province in which the supply is made EXPLANATION There are four participants in a supply of an electronically-arranged […][good] delivery service on [the Platform]: * [the Platform]; * a [merchant]; * a […][delivery driver]; and * a consumer. ...

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