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GST/HST Interpretation
17 September 2012 GST/HST Interpretation 145341 - Supplies under TIB B-32 and deemed supplies under section 172.1
. / 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. ... Issue 1 – Third Party pension expenses incurred by a participating employer of a pension plan SCENARIO: * […] ([…] [The Corporation]) is a registrant and a “participating employer” as defined in subsection 172.1(1). * The [Corporation] Pension Plan (the “Plan”) is a registered pension plan that governs a person that is a trust, and the trust is a “pension entity” of the Plan as defined in subsection 261.01(1). The pension entity is resident in Canada and a selected listed financial institution. * [The Corporation] entered into contracts with non-resident third parties (e.g., […] ([…] [A Co]) and […] ([…] [B Co])) to supply investment management services relating to “pension activities” (Footnote 1) of the Plan. ...
GST/HST Interpretation
25 March 1996 GST/HST Interpretation 11690-1 - Eligibility to Claim Input Tax Credits
25 March 1996 GST/HST Interpretation 11690-1- Eligibility to Claim Input Tax Credits Unedited CRA Tags ETA 145 Telephone #: (613) 954-8585 Fax #: (613) 990-1233 File #: 11690-1(glr) s. 145 XXXXX March 25, 1996 I refer to XXXXX note of June 9, 1995, addressed to Mr. ... I understand that: • XXXXX is a member of a partnership that consists of two other personal law corporations (PLCs) and the law firm of XXXXX[.] • XXXXX[.] • The PLCs each have management companies that charge the PLCs management fees, including the Goods and Services Tax (GST). • The PLCs were set up for the sole purpose of receiving the profits of the law firm. • The disbursements made to the PLCs are made under the terms of a partnership agreement and are not made at arm's length under the Income Tax Act. • All the above entities are currently registered for GST purposes. • XXXXX denied ITCs for the period beginning September 9, 1994, and ending October 30, 1994. ... Ryhorchuk GAD #: 1321(REG) imposition Team ...
GST/HST Ruling
29 September 2011 GST/HST Ruling 132884 - GST/HST RULING - Eligibility to claim public service body (PSB) rebates as a university and the tax status of supplies of short-term accommodation and parking
The [...] Act was assented to on [mm/dd/yyyy]. 2. According to section [...] of the [...] ... Under section [...] of the [...] Act [...]. [direct quote from legislation] 5. Under section [...] of the [...] Act [...]. [direct quote from legislation] 6. ...
GST/HST Ruling
1 June 2021 GST/HST Ruling 192033r2 - 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. ... On [mm/dd/yyyy], the Assignor and […](the Vendor) entered into an Agreement of Purchase and Sale ([…][the Agreement]) with respect to a residential condominium unit (the Unit) legally described as: […] with a municipal address of […]. 5. ... According to the Assignment Agreement: a) the Assignee was required to pay, to the Assignor, an assignment amount of $[…] for the assignment of [the Assignor’s] rights in [the Agreement]. […][An amount of]$[…] was payable [by the Assignee to the Assignor] as a deposit and the remaining balance of $[…] was payable [to the Assignor] on the Completion Date; b) the Assignee was required to pay, to the Developer, an assignment fee of $[…] plus [GST/HST]; c) the assignment amount included an amount to reimburse the Assignor for the Deposit of $[…] that was paid upon execution of [the Agreement] thus, the Assignor’s profit before commissions was $[…] (that is, $[…]- $[…] = $[…]); d) the Assignor was responsible for paying, to the Sub-agent, both the listing and selling agent portions of the commission in respect of the assignment of the Assignor’s rights in [the Agreement], which was a total of $[…] thus, the Assignor’s profit after commissions was $[…] (that is, $[…]- $[…] = $[…]); and e) the assignment amount (that is, $[…]) was inclusive of any [GST/HST] payable with respect to the assignment of the Assignor’s rights in [the Agreement], and the Assignor must remit any [GST/HST] payable. 13. ...
GST/HST Ruling
5 May 2022 GST/HST Ruling 230467 - Tax status of […][an application] fee [imposed by a municipality]
[The Municipality’s] [plan A] policies provide […] for […] Areas in addition to those set out in [plan B]. ... On [mm/dd/yyyy], [the Municipality] enacted and passed By-law [#] to amend the […], to establish […][a fee] of $[…] per […] request received from [mm/dd/yyyy] to [mm/dd/yyyy], inclusive. ... An application for an […] follows a similar, but separate, process from a […] request process. 15. ...
GST/HST Ruling
1 May 2015 GST/HST Ruling 164658 - Eligibility for input tax credits (ITCs) on amounts paid to law firm
For example, the Law Firm’s statements of account itemized the following services: * Drafting and issuing Statement of Claim; * Reviewing all pleadings; * Attendance at Examinations for Discovery; * All settlement negotiations; * Reviewing all accident benefits documentation; and * Settling of claim for civil damages. 4. The statement of account for [mm/dd/yyyy], indicates that the Law Firm received $[…] in trust as settlement and that the Law Firm’s fees of $[…], HST of $[…], and two other disbursements ($[…] paid to […][A] and $[…] paid to […][B]) were deducted from that amount and the remainder of $[…] was paid to you. 5. ... It shows that the Law Firm’s fees of $[…], HST of $[…], disbursements of $[…], and HST of $[…] were deducted from that amount and the remainder of $[…] was paid to you. 6. ...
GST/HST Interpretation
22 July 2004 GST/HST Interpretation 49110 - XXXXX
XXXXX • The Committee does not have a board of directors. • The Committee is not at arms length as it is responsible to the XXXXX and the Association. • XXXXX. At the end of its existence the Committee must provide reports of its activities to XXXXX. • The Association may be considered the parent body of the Committee but this is not known for certain. • The Committee does not have its own seal. • The Committee is not a separate legal entity. ... XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • The Association keeps records of the disbursements from the account for expenses incurred by the Committee. ...
GST/HST Ruling
19 April 2011 GST/HST Ruling 81203 - GST/HST treatment of trailer park site rental
The Park is located at [...] in [...], in the municipality of [...], [...] ... The unit measured [...]' x [...]', with an attached deck [...]' x [...]'. ... You were away from the Park [...] during the winter, generally during [...]. ...
Excise Ruling
1 March 2005 Excise Ruling 50105 - Exemption Request - Financial Guarantee Insurance
Question no 1- Un compte « J » permet-il à son titulaire d'acheter ou d'importer du carburant exonéré de la taxe d'accise? ... Un compte « J » ne permet pas à un client d'acheter ou d'importer du combustible diesel exonéré de la taxe d'accise. ... Le titulaire d'un compte « J » n'est pas considéré comme un fabricant aux fins de la LTA. ...
GST/HST Ruling
19 April 2011 GST/HST Ruling 127035 - Eligibility for a Point-of-Sale (POS) Rebate - Books
[The Franchisor] developed and is the owner [...] of [...]. 3. [The Franchisor] is the Franchisor of [...]. 4. Article [...] of the Franchise Agreement (the Agreement) states that [...]. 5. Article [...] of the Agreement states that [...]. 6. Article [...] of the Agreement outlines the obligations of the Franchisor [...]. 7. ...