Search - 江西农大 毛瑢

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GST/HST Interpretation

20 November 2002 GST/HST Interpretation 41962 - Whether Executors' Fees are Subject to GST

20 November 2002 GST/HST Interpretation 41962- Whether Executors' Fees are Subject to GST Unedited CRA Tags ETA 123(1) taxable supply; ETA 123(1) commercial activity; ETA 123(1) business; ETA 123(1) office Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXX Case Number: 41962File #: 11750-2November 20, 2002 Subject: GST/HST INTERPRETATION Whether Executors' Fees Are Subject to GST Dear XXXXX Thank you for your letter of XXXXX (with attachments) concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the fees paid by an estate to three executors appointed pursuant to the will of a deceased individual. ... You submit that based on the definitions of "taxable supply", "commercial activity", "business", and "office" in subsection 123(1) of the Excise Tax Act (the "ETA"), the definition of "office" in subsection 248(1) of the Income Tax Act, GST Question & Answer #3d.21, and a finding that in the cases of both the freelance bookkeeper and the lawyer the compensation would be income from an office under the Income Tax Act, the fees would not be subject to GST. 7. In your view the position of the CCRA outlined in GST Question & Answer #3d.21 is not clear with respect to the freelance bookkeeper and the lawyer because the bookkeeper was appointed executor due to XXXXX past working relationship with the deceased individual (i.e. ...
GST/HST Interpretation

29 July 2003 GST/HST Interpretation 46768 - GST/HST on Domestic Packaged Wine

In addition, paragraph 154(2)(a) of the ETA provides that the consideration for the supply of wine includes any "... duty... imposed under an Act of Parliament... that is... payable or collectible by the supplier, in respect of that supply or in respect of the production, importation, consumption or use of the property... ... Yours truly, Susan Kissner Specialty Tax Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate Legislative References: •   Excise Tax Act (ETA): subsection 123(1) definitions of consideration, supply; sections 133; 134; 154; 165;•           Excise Act, 2001 (EA1) June 13, 2002 Royal Assent / July 1, 2003 implementation date): section 2 definitions of alcohol ii1, beer, spirits, wine; Part IV (Alcohol): sections 59-158, subsection 135(3), 138(2); sections 136, 137, 139.•       Excise Act R.S., c. ...
GST/HST Interpretation

8 January 2003 GST/HST Interpretation 43463 - Payments Made to Clergy, Church Organists and Soloist/Musicians

There are two distinct situations: •   The clergy makes no specific request for payment for performing a funeral service, however, the family decides to make a donation through the funeral home that is providing the funeral arrangement. The payment by the funeral home is done as a service to the family and no money is retained by the funeral home for this service; and •   There is an amount specified by the clergy, which is then forwarded, again, through the funeral home to the Church or clergy. ... Yours truly, Carolle Mercier Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate ...
GST/HST Interpretation

28 March 2024 GST/HST Interpretation 245855 - Nurse placement agencies

. / 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. ... INTERPRETATION REQUESTED You would like to know the Canada Revenue Agency position concerning the application of the GST/HST to the supply, by a placement agency, of nursing personnel to nursing homes and hospitals (the health care facilities) further to the decision A-Supreme Nursing & Home Care Services Inc. v. ... If yes, who assumes the responsibility the agency or the health care facility? ...
GST/HST Interpretation

17 July 2024 GST/HST Interpretation 245893 - Supply of short-term accommodation through an accommodation platform

. / 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. ... You are a currently making supplies of short-term accommodation of a home […], in […][a non-participating province A]. 2. ... In [mm/yyyy], [the Company] began to send you invoices labelled as […] for GST amounts on prior transactions. ...
GST/HST Interpretation

9 April 2025 GST/HST Interpretation 247209 - Mining activities in respect of cryptoassets after February 4, 2022 via mining pools

Accordingly, our comments below are limited to those circumstances. […]. ... A CSP receives payment in the form of [cryptoasset] based on the estimated revenue calculation […]. ... In a FPPS payment arrangement, generally the Operator bears the risk associated with mining a block […]. ...
GST/HST Interpretation

25 June 2024 GST/HST Interpretation 246382 - Mining activities in respect of cryptoassets concerning mining pools

Accordingly, our comments below are limited to those circumstances. […]. ... A CSP receives payment in the form of [cryptoasset] based on the estimated revenue calculation […]. ... In a FPPS payment arrangement, generally the Operator bears the risk associated with mining a block […]. ...
GST/HST Interpretation

6 July 2021 GST/HST Interpretation 206211 - Assignment of an agreement of purchase and sale of a condominium unit

. / 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. ... The Assignor purchased the condo approximately [#] years ago ([yyyy]). ... The Assignor decided to sell the Unit in [yyyy], and therefore, entered into an Assignment of Contract of purchase and sale (the Assignment Agreement) with respect to the Unit, which generated $[…] in proceeds for the Assignor. ...
GST/HST Interpretation

26 August 1994 GST/HST Interpretation 11745-5(on)[3] - Supplies of Leased Motor Vehicles

26 August 1994 GST/HST Interpretation 11745-5(on)[3]- Supplies of Leased Motor Vehicles Unedited CRA Tags ETA 340(3)                                                                         Telephone: (613) 954-8585 Fax: (613) 990-3602 XXXXX File: 11745-5(on), ss. 340(3)                                                                         August 26, 1994 Dear Mr. ...
GST/HST Interpretation

16 October 1997 GST/HST Interpretation HQR0000011 - Returnable Containers

16 October 1997 GST/HST Interpretation HQR0000011- Returnable Containers Unedited CRA Tags ETA 226  XXXXX GST/HST Rulings  XXXXX                and Interpretations Directorate  XXXXX                25, McArthur Avenue  XXXXX                Vanier (Ontario)  XXXXX                K1A 0L5                                                                         File: 11610-7(rl) Section 226 HQR0000011                                                                         October 16, 1997 Dear XXXXX This letter is in response to the memorandum (attached) sent to XXXXX. ... Let us say that the normal period of storage between acquisition and resupply is one month, and that all the taxable containers are taxable because they are supplied at a price superior to the ones they were acquired, let us say, with a mark-up of 10%, that means that the month after the acquisition, there should have been a taxable supply of empty containers corresponding to a tax-included amount of $32,100 + ($32,100 x 10%), which is $32,100 + $3,200, i.e., $35,300. ...

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