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GST/HST Ruling
7 February 2022 GST/HST Ruling 210585 - Application of the GST/HST to the supply made by a minor hockey association of registering a participant in a minor hockey program
It states, “[…]” 4. The Program consists of the following age groups. ... The Manual states the following on the subject of registration fees charged by the Association for participation in the Program, […] Items to be included in the cost of registration fees shall include: • […] Player Insurance • Ice Costs • Jersey Fund • Socks • Pictures • Administration 8. ... A supply will be exempt under section 12 of Part VI of Schedule V where: * The supplier is a public sector body (which is defined to include a non-profit organization); * The supply is of a membership in a program or services supplied as part of a program; * The program is established and operated by the public sector body; * The program consists of a series of supervised instructional classes or activities involving athletics, outdoor recreation, music, dance, arts, crafts or other hobbies or recreational pursuits; * One of the following circumstances applies: * The program is provided primarily to children 14 years of age or under and it does not involve overnight supervision throughout a substantial part of the program; or * The program is provided primarily to underprivileged individuals or individuals with a disability. ...
GST/HST Ruling
29 January 2015 GST/HST Ruling 93176 - GST/HST on fees relating to a loan
You provided a copy of the following documentation: * 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], 2013, addressed to [CCo] and signed by […] on behalf of [BCo]. ... 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: […] 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. ... On [mm/dd/yyyy], [ACo], [CCo], and [BCo] entered into an Assignment Agreement (Assignment Agreement) which contained the following provisions: * Pursuant to the Term Sheet, [ACo] agrees to make certain loans and advances to [BCo], subject to the terms and conditions of the Term Sheet (the “Credit Facilities”); * Pursuant to terms of the Term Sheet, [ACo] has the discretion as to the entity that will enter into the loan arrangements with [BCo] and fund the advances made to [BCo] pursuant to the Term Sheet; * [ACo] has designated [CCo] as the Lender under the Term Sheet; * For consideration of $[…] paid by [CCo] to [ACo], [ACo] assigns to [CCo] all of its right, title and interest in the Term Sheet and the Credit Facilities. * [ACo] represents that the Term Sheet is in full force and effect and unamended and [ACo] has not knowingly discharged [BCo] from the Term Sheet or assigned any rights or obligations under the Term Sheet; * [CCo] accepts the assignment of [ACo]’s rights and obligations in the Term Sheet and indemnifies [ACo] from any claims by [BCo] arising in connection with the Term Sheet or the performance of the Lender’s obligations under the Term Sheet; * [BCo] acknowledges that it has taken notice of the assignment and expressly consents to it. * The Assignment Agreement sets forth the entire agreement and understanding among the parties with respect to the subject matter and supersedes any prior agreements or understandings, whether oral or in writing. ...
GST/HST Ruling
29 August 2011 GST/HST Ruling 81229 - GST/HST RULING - GST/HST treatment of trailer park site rental
The Park is located at [...] in [...] [Community 1], in the municipality of [...], [...] ... You own your unit, a [...] park model, which measures [...]' x [...]'. ... The site is fully landscaped and has a [...]' x [...]' concrete driveway. ...
GST/HST Ruling
14 February 2024 GST/HST Ruling 246201 - /INTERPRETATION - Supplies made through a distribution platform
Section [#] […]. f. Section [#] […][Information about the relationship between the parties]. ... As a consideration for the supply, [the Company] will generally pay the Creator in the form of a fixed amount (USD $[…]) calculated on the [X] awarded to the Creator […] and a share of net subscription revenues […]. ... This information is available in the GST/HST registry database maintained by the CRA at canada.ca/en/revenue-agency/services/tax/businesses/topics/gst-hst-businesses/digital-economy-gsthst/confirming-simplified-gst-hst-account-number 3. […] 4. […] 5. […] 6. […] 7. […] 8. […] 9. […] 10. […] 11. […] 12. […] 13. […] 14. […] 15. […] ...
GST/HST Interpretation
17 May 2012 GST/HST Interpretation 62492 - Application of the GST/HST to point-of-sale terminal fees
Provided with [the enquiry] are the following agreements for our review: * […][Agreement 1] dated [mm/dd/yyyy], between [the ISO] and […][(the Merchant)], a merchant located in [City 1, Province 1] […]. * […][Agreement 2], dated [mm/dd/yyyy], between [the ISO] and […][(Representative)], a sales representative located in [City 1, Province 1][…]. * […][Agreement 3] and […], […][Agreement 4] both dated [mm/dd/yyyy], between [the ISO] and ([…][Company A]), a company located in [City 2, Province 2]. ... In particular, the ISO provides the following services to the Merchant under [Agreement 1]: * provide continuous processing services to […]; * provide monthly reports of activity […]; and * settle all cash transactions […]. The Merchant agrees under [Agreement 1] to, among other things: * use the ISO for support, data processing, and funds transfer services exclusively; * charge a user fee to its customers at the POS Terminal equal to $[…] per transaction; * pay from the fees generated per transaction: an amount equal to […]% to the ISO for its services; $[…] and $[…] to the Acquirer for each respective complete and incomplete debit transaction; and a processing charge to the Acquirer for credit transactions varying from $[…] to $[…] depending on the credit arrangement; * provide access to a bank account for the purposes of settling cash transactions; * provide any documentation or other assistance to the ISO to assist in resolving any processing adjustments, […]; and * monitor the operation of the POS Terminal. ...
GST/HST Ruling
25 May 2021 GST/HST Ruling 204710 - Amounts paid to a municipality pursuant to a licence agreement
These programs include the maintenance and servicing [by ACo] of […][X], including installation, repair and replacement, and […]. 4. […]. ... The term of [the Agreement] is […] commencing [mm/dd/yyyy] and ending on [mm/dd/yyyy], […]. 7. ... According to […] [the Agreement], [ACo] will pay […] to [the Municipality] […] for the duration of the agreement. […] 9. […][Other matters clarified in the Agreement]. 10. ...
GST/HST Ruling
10 October 2012 GST/HST Ruling 147921 - Value of temporary importation of leased bus
. / 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. ... We understand that: * […] (the “Lessee”) has entered into an agreement to lease the following bus from […] (the “Lessor”), a non-resident person with whom the Lessee deals at arm’s length: Bus Type Model Number Serial Number Registration Number […] Not applicable […] Not applicable * The lease agreement is for a period beginning on [mm/dd/yyyy] and ending on [mm/dd/yyyy]. * The bus will be imported at […] on [mm/dd/yyyy] and will be exported on [mm/dd/yyyy]. * The total number of months that the bus is to be held in Canada by the Lessee under a lease with the Lessor will not exceed 24 months. ... A copy of this letter has been sent to the Canada Border Services Agency, Canada Border Services Office […]. ...
GST/HST Interpretation
19 June 2019 GST/HST Interpretation 197123 - Documentary requirements for claiming input tax credits
INTERPRETATIONS REQUESTED You have provided […] documentation to support […] ITC claims in the circumstances described in points 1 to 5 above and requested […][our] interpretation of the legislation in each case. ... Supporting documentation for purchases totalling less than $150 […]. […] The name of the recipient is not prescribed information for purposes of paragraph 169(4)(a), according to either paragraph 3(a) or (b) of the Regulations. ... Entitlement to claim ITCs where the taxpayer’s trade name is listed on the invoice […]. ...
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 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. ...