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GST/HST Interpretation

1 July 1997 GST/HST Interpretation HQR0000519 - Section 153(4) - The "Trade-in Approach"

Selling price of new vehicle $21 000.00 Less: Residual value (buy out option) 10 600.00 Net difference $10 400.00 Less: Trade-in allowance 5 000.00 Amount depreciated over 36 term lease (LDV) 5 400.00 Add: Loan repayment $0.00 Gross amount owed to lessor by lessee 5 400.00 Monthly lease payment Monthly depreciation ($5,400/36) $     150.00 Add: Interest charge 88.90 $     238.90 Add: GST ($238.90 x 0.07) 16.72 Total amount per month lessee remits to lessor   $     255.62 Response: The above calculation of the amount of GST on each lease payment ($16.72) is correct. ... Selling price of new vehicle $21 000.00 Less: Residual value (buy out option) 10 600.00 Net difference $10 400.00 Less: Trade-in allowance 5 000.00 Amount depreciated over 36 term lease (LDV) 5 400.00 Add: Loan repayment 3 000.00 Gross amount owed to lessor by lessee 8 400.00 Monthly lease payment Monthly depreciation ($5,400/36)  $     150.00 Add: Interest charge 88.90 $     238.90 Add: GST ($238.90 x 0.07) 16.72 Amount per month lessee remits to lessor re lease $     255.62 Monthly loan payment Monthly principal repayment (3,000/36) $       83.33 Add: Interest factor for loan amount 10.50 $       93.83 Total amount per month lessee remits to lessor $     349.45 Response: The above calculation of the amount of GST on each lease payment ($16.72) is correct. ... Selling price of new vehicle $21 000.00 Less: Residual value (buy out option) 10 600.00 Net difference $10 400.00 Less: Trade-in allowance Initial value $12,000.00 Amount of trade-in allowed on lease 10 400.00 Amount given to owner in cash 1,600.00 Amount depreciated over 36 term lease (LDV) $         0.00 Add: Loan repayment 8 000.00 Gross amount owed to lessor by lessee 8 000.00 Monthly lease payment Monthly depreciation ($0) $         0.00 Add: Interest charge 70.00 $       70.00 Add: GST ($70.00 x 0.07) 4.90 Total amount per month lessee remits to lessor, re lease $       74.90 Monthly loan payment Monthly principal repayment (8,000.36) $     222.22 Add: Interest factor for loan amount 28.00 $     250.22 Total amount per month lessee remits to lessor $325.12 Response: The above calculation of the amount of GST on each lease payment ($4.90) is correct. ...
GST/HST Interpretation

5 July 2012 GST/HST Interpretation 119159 - Closely related corporations

The societies provide [supplies of] […]. The reason there are several societies is that there are different funders. […] The societies are each incorporated under the […] Act of [province A] […]. ... Under section […] of the […] Act, […]. Thus, as a society incorporated under that Act does not have capital that is divided into shares, it cannot be owned by another society and therefore cannot be closely related to another society for purposes of section 128. ... This would not likely be the case for a society which is engaged in the provision of exempt [supplies of] […]. ...
GST/HST Interpretation

8 March 1996 GST/HST Interpretation 11715 - GST Status of "Royalty" Payments

8 March 1996 GST/HST Interpretation 11715- GST Status of "Royalty" Payments Unedited CRA Tags ETA Sch VI, Part I, 2(b)                                                                         #11715, # 11755-20                                                                         P. ... This exclusive right is different and distinct from the Drugs, and it is clearly NOT "a drug included in Schedule F to the Food and Drug Regulations ". ... The sale of the Drugs can be made to XXXXX without the granting of the Right at the same time (e.g. see paragraph (6) of the XXXXX agreement). •   The sale of the Drugs and the granting of the Right are NOT interconnected, interdependent or intertwining each other. •   Each of the supplies is provided separately in the Agreements, and the consideration for each of the supplies is calculated separately. •   The Drugs and the Right are acquired by XXXXX for different and unrelated use. ...
GST/HST Interpretation

2 July 1996 GST/HST Interpretation 11680-1[3] - Application of the GST to the Lease and Purchase of a Van

2 July 1996 GST/HST Interpretation 11680-1[3]- Application of the GST to the Lease and Purchase of a Van Unedited CRA Tags ETA 133(a); ETA 136(1); ETA 142(1)(b); ETA 142(2)(a); ETA 142(2)(b); ETA 165(1); ETA 232; ETA 261                                                                         Telephone #: (613) 954-8585 Fax #: (613) 990-1233 XXXXX                                                                                 File #: 11680-1(glr) XXXXX                                                                                 s. 133, 136, 142, 165, 261 XXXXX                                                                                 July 2, 1996 ATTENTION: XXXXX I refer to XXXXX E-mail message of June 18, 1996, addressed to Ms. ... The following information was provided by XXXXX •   XXXXX, XXXXX, a resident of XXXXX at that time, entered into an agreement to lease a XXXXX van from XXXXX[.] •   The monthly lease payments as specified in the agreement were XXXXX plus XXXXX GST. •   XXXXX, XXXXX moved to XXXXX and took the van with him. •   XXXXX continued to pay the GST on the lease payments, even after he relocated to XXXXX[.] •   XXXXX, XXXXX exercised the purchase option contained in the lease and purchased the van from XXXXX[.] ... Nanner        GOBI #: 1775(REG) G. Ryhorchuk ...
GST/HST Interpretation

28 April 2000 GST/HST Interpretation 30301 - The Zero-Rating of Training Services Supplied by

The agreement provides that XXXXX will render the training services to XXXXX who will travel to Canada on student visas. •   The XXXXX can choose to register with XXXXX under the XXXXX[.] Those students who wish to enroll in either program pay a tuition to XXXXX which includes accommodation and meals supplied at XXXXX facilities. •   XXXXX invoices XXXXX for the budgeted costs to administer these programs plus an additional amount per student, on a cost-plus contract, for services rendered. •   The XXXXX who successfully complete the XXXXX receive XXXXX while the students who successfully complete the XXXXX[.] •   The students are XXXXX residents who enter Canada under a student visa only and return to XXXXX upon completion of their studies. ... For further information, please refer to Policy Statements P-229 and P-231, entitled " Definition of "Vocational School ["]" and " Courses that Qualify for Exemption ", respectively. ...
GST/HST Interpretation

31 March 2014 GST/HST Interpretation 143163 - Application of the GST/HST to the supply of a right of entry or user under section 162

. / 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 Landowner provided two sample Agreements: a. […] Agreement [1] between the Landowner and […] (Disposal Co. 1) acting as agent for […] (Oil Co. 1). b. […] Agreement [2] between the Landowner and […] (Disposal Co. 2) acting as agent for […] (Oil Co. 2). 4. ... The Disposal Co. enters into […] Agreement [3] with the Landowner to dispose of drilling waste which is a byproduct of Oil Co. exercising that right. ...
GST/HST Interpretation

30 October 1997 GST/HST Interpretation HQR0000587 - Materials Supplied With Correspondence Courses

Based on the information provided and a "single vs. multiple supplies" analysis as set out in Policy P-077, our interpretation as to whether the supplies listed in b) through i) in Fact 5 are an element of a single supply of instruction or a separate supply is as follows: •   lesson materials which relate to the courses: an element of a single supply of instruction; •   textbooks: a separate supply; •   novels: a separate supply; •   laboratory kits: a separate supply; •   deposits on loan kits: a separate supply; •   compulsory audiocassettes: an element of a single supply of instruction; •   optional audiocassettes: a separate supply; •   deposits on compulsory videocassettes: an element of a single supply of instruction; •   deposits on optional videocassettes: a separate supply; •   computer disks: a separate supply. 2. ... Such an analysis would include discussions of the following concepts: •   inputs vs. supplies; •   number of suppliers/recipients; and •   terms of invoice/contract/agreement. ... In order to categorize or determine the nature of the supply, the following criteria may be used: •   description of the supply; •   objective of the supply; •   agreement between the parties; •   intent of purchaser. ...
GST/HST Interpretation

18 March 2013 GST/HST Interpretation 134610 - Meaning of "therapeutic health care services"

The Society provides a wide range of services to seniors in the […] [City A], […] [Province A] area, from low income housing to long-term residential care for seniors with complex care needs. […] The Society is registered for GST/HST purposes and has been assigned the business number […]. ... In that regard, the 2005 Federal Budget document, 2005 Budget Plan Annex 8 Tax Measures: Supplementary Information, contains the following comments: The proposed measure, which accommodates the significant variations in health care delivery models across the country, will expand the 83-per-cent rebate to eligible facilities and entities that belong to the following categories: •     Ambulatory care hospitals, which currently do not qualify for the hospital rebate because they do not have in-patient beds, and day surgery clinics. •     Cancer clinics and other specialized clinics that provide care such as mental health or HIV programs. •     Community health centres. •     Facilities that offer high-level therapeutic care. •     Organizations that provide medical care to individuals in their homes. •     Regional health authorities that support the delivery of health care within their regions. •     Entities that provide ancillary support, such as laboratory and diagnostic services and centralized laundry and in-patient meal services, to health care facilities. ... Ensemble de procédés de traitement.     ...
GST/HST Interpretation

12 March 1996 GST/HST Interpretation 11650-6[3] - Employee and Partner GST Rebate Calculation for Members of a Partnership

12 March 1996 GST/HST Interpretation 11650-6[3]- Employee and Partner GST Rebate Calculation for Members of a Partnership Unedited CRA Tags ETA 253                                                                         Telephone: (613) 954-8585                                                                         Fax: (613) 990-1233                                                                         11650-6 (pl)                                                                         Section 253 XXXXX March 12, 1996 Dear Mr. ... You believe that the GST rebate calculation for this period would be based on the eligible expenses deducted in the period by the partner for income tax purposes less any amount claimed as a reserve by the partner; •   You also provided in your facsimile the following illustrative example of a partner's GST rebate claim for 1995 based on the aforementioned facts: XXXXX XXXXX XXXXX XXXXX Your questions are: •   whether the above interpretation (and illustrative example) is correct; and if so, •   whether the Department would consider allowing a full GST rebate in respect of the eligible expenses incurred in the second period (i.e, from Feb. 1, 1995 to Dec. 31, 1995) to be claimed in the 1995 taxation year rather than over the ten year transitional period. ... Jones Director General Applications Division GST Rulings and Interpretations GAD #: 2746 (GEN) c.c.: M. ...
GST/HST Interpretation

26 June 2012 GST/HST Interpretation 109656 - Dance lessons as vocational courses under the ETA

. / 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. ... RULING REQUESTED Your client has previously been provided two rulings on this matter by two of our field offices. […] We have reviewed your letter as well as the information provided by your client respecting this file. ... The [CRA] does not consider the following courses to develop or enhance a student's occupational skills: * sports * games * hobbies; or * other recreational or cultural pursuits, that are designed for personal interest. ...

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