Search - 辐射监测仪 校准

Statement of Facts Our understanding of the facts based on your letter and our subsequent telephone discussions is as follows: •   XXXXX is a non-resident vendor of goods based in XXXXX, US. •   XXXXX acquires the goods on a delivered in Canada basis from XXXXX, a GST/HST registered non-resident company. •   The goods acquired by XXXXX are manufactured and packaged in XXXXX US. by XXXXX and delivered to XXXXX on a FOB XXXXX basis. •   XXXXX has contracted with XXXXX to store the goods until they are sold. •   XXXXX has XXXXX Canadian clients for the goods XXXXX. ... The factors to consider in determining whether, for GST/HST purposes, a non-resident person is carrying on business in Canada in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed, and •   the place of manufacture or production. ... Yours truly, Jeff Frobel Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2007/01/10 — RITS 82341 — Eligibility to Claim Input Tax Credits (ITCs) in Respect of Hedging Activities ...

. / 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 if the activities listed below, if undertaken by any one of your Canadian network offices on a global policy covering Canadian risks, would be sufficient to enable them to be viewed as the broker through whom insurance contracts are entered into or renewed for Excise Tax purposes. • Collecting insured data; • Developing program strategy/design; • Advising on local legal, regulatory and insurance practices; • Producing policy wordings; • Presenting proposal/terms to the insured; • Issuance of documents; • Invoicing of local premium; and • Local tax settlement. ...

The Park is located [...] in the municipality of [...] [Participating Province X]. ... It has a total of [...] sites. [...] of the sites are for transient campers. ... For example, the unit on Lot [...] is described as [...]. Sale prices for these units range from $[...] to $[...]. ...

Tour 1 includes between [#] and [#] nights of accommodation in Canada. ... Tour 2 includes between [#] and [#] nights of accommodation in Canada. ... Tour 3 includes between [#] and [#] nights of accommodation in Canada. ...

Residents at the Facility have various health care conditions including Parkinson’s disease, cancer, acquired brain injuries, MS, or are post-stroke. […] percent ([…]%) of residents ([#]) are incontinent; […] percent ([…]%) of residents ([#]) experience a form of dementia or related cognitive impairments. […] 10. ... Appendix […] to the agreement reads as follows: […] 12. The physicians each work […] hours a week and will visit residents under their care at least […]. ... Residents at the Facility receive physiotherapy […] and […] dietary services […]. ...

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Statement of Facts •   XXXXX. •   The Company is a Canadian tour operator who resells XXXXX blocks of hotel rooms XXXXX to non-registrant non-resident tour operators XXXXX. •   XXXXX. •   After, July 1, 2006, the Company received an invoice from the hotel for short-term accommodation and was charged GST at 6%. •   XXXXX. ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2006/07/28 — RITS 81356 — Application of GST/HST to Cemetery Products and Services ...

Some examples of services include: •   guide or interpreter services; •   transportation services (e.g., air travel); •   sightseeing excursions; and •   ski lessons. ... The following do not qualify as services as they are property: •   short-term and camping accommodation; •   meals; •   a right to enter or attend an event, such as tickets to a show or a hockey game; •   car rentals; •   ski rentals; •   ski lift passes; •   golf green fees; and •   park passes. ... These persons are: •   a non-resident consumer; •   a non-resident non-registered tour operator; and •   a non-resident non-registered business or organization that is not a tour operator. ...

STATEMENT OF FACTS Our understanding of the facts based upon your submission of September 26, 2013 and our subsequent conversations […], is as follows: 1. […]. ... According to section […] of the Plan, […], all normal and reasonable expenses incurred in the operation of the Plan and all taxes levied or assessed with respect to the Pension Fund may, at the discretion of [A Co] as the Administrator, be paid from the Pension Fund. 10. […]. 11. ... An example of the discharging of such an expense for which [A Co] has contracted with [C Co] and for which you wish to claim an ITC is as follows: * Sample invoice [#] dated [mm/dd/yyyy], for the amount of $[…] plus $[…] […][GST/HST] was issued to [A Co] from [C Co], a pension consulting firm. * Work is completed by the pension consultant, [C Co]. * The invoice is sent to [A Co] for payment. * The Vice President of Human Resources reviews and approves the invoice for payment. * The Plan service provider, [B Co] is then notified that the funds can be taken from the Plan for payment. * Invoice is paid by the Plan to [C Co]. ...

Specifically, we received the following documents: a.) your incoming letter; b.) […] (Lender 1) documents: i.) […] (the Lender 1 Dealer Agreement), […], and ii.) […] (the Lender 1 Contract); c.) […] (Lender 2) documents: i.) […] (the Lender 2 Dealer Agreement), and ii.) […] (the Lender 2 Contract); d.) […] (Lender 3) documents: i.) […] (the Lender 3 Dealer Agreement), and ii.) […] (the Lender 3 Contract); e.) […] (Lender 4) documents: i.) […] (the Lender 4 Dealer Agreement), ii.) […] (the Lender 4 Contract), and iii.) […][another contract] with similar terms as the Lender 4 Contract, and therefore not referenced in the balance of this response; f.) […] (the Lender 5 Contract); g.) […] (the Lender 6 Contract); h.) […] (the Lender 7 Contract); and, i.) […] (the Lender 8 Contract). ... The key provisions in these transactions, based on the documentation we received, are: * the contract is intended to be assigned to a lender; * upon assignment, the lender is receiving an assignment of a flow of payments provided under the contract (e.g., all amounts due now and over time); * upon assignment, the Dealer is to receive a payment based on the amount to be financed by a customer under the contract; and * the Dealer receives a fee in respect of the assignment of the contract. ... We further rule that a Fee received by the Dealer from * Lender 1 for the assignment of rights under the Lender 1 Contract, * Lender 3 for the assignment of rights under the Lender 3 Contract, or * Lender 4 for the assignment of rights under the Lender 4 Contract forms part of the consideration received for the assignment of the specific Contract, and therefore would not be subject to GST/HST as the assignment is an exempt supply. ...