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GST/HST Ruling

28 March 2003 GST/HST Ruling 40372 - Internet Advertising

The "commission" is equal to XXXXX % of the retail sale price of each product sold, excluding shipping charges. 9. XXXXX forwards to the vendor any payment received in respect of the sale of the products made through its Web site less the XXXXX % amount it retains. 10. ... Under the XXXXX Agreement, XXXXX is supplying an advertising service to the vendor; 2. the supply of the advertising service is made in Canada and is subject to the GST at a rate of 7% when the service is provided to a vendor who is resident in Canada; 3. when the supply of the advertising service is made to a non-resident person, that supply is zero-rated (i.e., taxed at a rate of 0%) pursuant to section 7 or section 8 of Part V of Schedule VI to the Excise Tax Act (ETA); and 4. the XXXXX % amount charged by XXXXX to a vendor is additional consideration in respect of the advertising service and will have the same tax treatment as described above. ...
GST/HST Ruling

9 March 2023 GST/HST Ruling 244638 - Acting as an Intermediary Between a Merchant and an Acquirer under a Payment Card Network

. / 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. GST/HST Rulings Directorate Place de Ville, Tower A, 5th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 244638 Dear [Client]: Subject: GST/HST RULING Acting as an Intermediary Between a Merchant and an Acquirer under a Payment Card Network Thank you for your letter of [mm/dd/yyyy], in which you requested a ruling on behalf of […] (the “Company”), with respect to the application of the goods and services tax/harmonized sales tax (GST/HST) to the services supplied by the Company. ... STATEMENT OF FACTS For the purposes of your ruling request, you provided us with electronic copies of the following documents: Merchant Agreement between […][ACo] and a retailer (herein, the “Sample Merchant Agreement”) […] Agreement between the Company and [ACo] ([…][Agreement X]) Based on the information contained in your letter, the above documents and our telephone conversation of [mm/dd/yyyy], we understand the following: 1. ...
GST/HST Interpretation

17 June 2024 GST/HST Interpretation 203070 - Application to Bitcoin Mining and the Sale of Bitcoins

. / 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. ... Subsection 188.2(5) provides an exclusion to subsection 188.2(2) to (4) to the extent that the mining activity is performed by a particular person for another person if (a) the identity of the other person is known to the particular person; (b) where the mining activity is in respect of a mining group that includes the particular person, the other person is not a mining group operator in respect of the mining group; and (c) where the other person is a non-resident person and is not dealing at arm’s length with the particular person, each property or service being property or a service that is received by the other person from the particular person as a consequence of the performance of the mining activity is supplied, or is used or consumed in the course of making a supply, by the other person to one or more persons each of which (i) is a person whose identity is known to the other person, (ii) deals at arm’s length with the other person, and (iii) is not a mining group operator in respect of a mining group that includes the other person if the mining activity is in respect of that mining group.” ...
GST/HST Interpretation

14 August 2024 GST/HST Interpretation 247708 - […][the Company] and the purpose-built rental housing (PBRH) rebate

. / 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. GST/HST Rulings Directorate 5th floor, Tower A, Place de Ville 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 247708 Business Number: […] Dear [Client]: Subject: GST/HST interpretation- […][the Company] and the purpose-built rental housing (PBRH) rebate Thank you for your correspondence of May 21, 2024, concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to […][the Company] and their eligibility to claim the PBRH rebate. ... As discussed […], we are issuing an interpretation for this ruling request, which is a general explanation of the applicable provisions and how the legislation will apply. ...
GST/HST Ruling

18 May 2018 GST/HST Ruling 166774 - Application of GST to supplies sales of medical marihuana

. / 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. Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 11th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 166774 Business Number: […] Dear [Client]: Subject: GST/HST RULING Application of GST to supplies sales of medical marihuana Thank you for your fax of November 27, 2014, concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to sales of dried marihuana made by […] (the Business). ... The Business is a commercial producer of various strains of dried marihuana for medical purposes and operates a facility located in […][City 1, Province A]. […]. ...
GST/HST Interpretation

25 November 1994 GST/HST Interpretation 1870-4-2 - the GST New Housing Rebate

The clause stated that, "... the Purchaser shall, nevertheless, take possession of the Unit... ... Some key points of this Agreement are as follows: •   "It is understood and agreed that all amounts paid by the Purchaser by way of occupancy fees are not to be credited to the Purchaser as payments on account of the purchase price, but shall be payable as occupancy fees only." •   "The Purchaser shall use the Unit only as a single family dwelling and he will not take in borders and/or roomers nor grant occupation to the Unit to any other parties whatsoever. ...
GST/HST Interpretation

13 September 2023 GST/HST Interpretation 245240 - Emission Allowance

. / 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. ... Subsection 5(1) of the Regulations [specifies the CI limits (gCO2e/MJ) for each compliance period for 2023 to 2030 and beyond in the Fuel Carbon-Intensity Limits table and] states that a primary supplier’s pool …of a liquid fossil fuel that is set out in Column 1 of the table […] must not have a CI that is greater than the corresponding limit set out in Column 2 [of the table] for the corresponding compliance period. […] Subsection 1(1) of the Regulations defines a compliance period, in part, to mean January 1, 2023 to June 30, 2023; July 1, 2023 to December 31, 2023, and then each calendar year thereafter. 4. ... Subsection 23(2) of the Regulations states that a primary supplier must not use a provisional compliance credit to satisfy a total reduction requirement and must not transfer a provisional compliance credit under the CCTS. 14. ...
GST/HST Interpretation

13 September 2023 GST/HST Interpretation 245635 - Emission Allowance

. / 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. ... Subsection 5(1) of the Regulations [specifies the CI limits (gCO2e/MJ) for each compliance period for 2023 to 2030 and beyond in the Fuel Carbon-Intensity Limits table and] states that a primary supplier’s pool …of a liquid fossil fuel that is set out in Column 1 of the table […] must not have a CI that is greater than the corresponding limit set out in Column 2 [of the table] for the corresponding compliance period. […] Subsection 1(1) of the Regulations defines a compliance period, in part, to mean January 1, 2023 to June 30, 2023; July 1, 2023 to December 31, 2023, and then each calendar year thereafter. 4. ... Subsection 23(2) of the Regulations states that a primary supplier must not use a provisional compliance credit to satisfy a total reduction requirement and must not transfer a provisional compliance credit under the CCTS. 14. ...
GST/HST Interpretation

7 August 2019 GST/HST Interpretation 197932 - Municipal designation

In [yyyy], the [#] families in the mobile home park decided to create a Cooperative, which acquired the mobile home park from the landowner. 3. ... The rental cost set out is a global amount of $[…] per month. This amount is not allocated by service. ... Therefore, it can be designated as a municipality under the definition of “municipality” in subsection 259(1) […]. 3. ...
GST/HST Ruling

24 February 2022 GST/HST Ruling 231316 - The application of the “qualifying health care supply” purpose test and the tax status of occupational health services and travel health consultation services

. / 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. ... STATEMENT OF FACTS We understand the following: 1. […] (the Corporation) carries on a healthcare service business […][in Canada]. 2. It is registered for GST/HST under account number […]. 3. Among other services, the Corporation offers occupational health services, travel health consultation services and vaccinations to their clients [at a clinic located in Canada]. 4. ...

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