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GST/HST Ruling
19 June 2012 GST/HST Ruling 145130 - Band-empowered entity
STATEMENT OF FACTS * […] * [The Corporation] is responsible for providing comprehensive health services in the […] and […] regions in […][Province 1] servicing [#] communities: […]. * […] is located in the town of […][City 1, Province 1]. It includes the […] located on the […] Indian reserve and the […] located on the […] reserve. * […]. * […]. * [The Corporation] is registered as a charitable organization under the category “Hospitals” by the Charities directorate of the CRA as of [mm/dd/yyyy]. (BN# […]) * [The Corporation] was incorporated as a corporation without share capital in [yyyy]. * Head office of the corporation is located on the […] Indian reserve […]. * By-Law […], Membership states: At all times the Directors described in Section 4.1(1)(a) through Section 4.1(1)(f) shall be members. * By-Law […], Composition of the Board states: The Board of Directors of the [the Corporation] is composed of [#] elected directors and [#] ex officio directors, including: […] * By-Law […], Elected Directors states: […] At the first election of Directors following approval of this By-Law, [#] directors shall be elected for a [#]-year term, [#] Directors shall be elected for a [#]-year term, and [#] Directors shall be elected for a [#]-year term. ...
GST/HST Ruling
12 March 2013 GST/HST Ruling 133588 - Public Service Body Rebate of the Provincial Part of the HST– [Whether resident in a province]
[The Charity] has entered into […] [Agreement A] with […] [the consultant], located in […], [Participating Province Y]. […] 10. ... " * […] [Details of Agreement A] 11. Pursuant to [Agreement A] […]. 12. ... [The Charity] entered into […] [Agreement B], dated [mm/dd/yyyy], with […] [Participating Province Y] […]. 16. […]. 17. […] [Details relevant to Agreement B] 18. […] [Details relevant to Agreement B] 19. ...
Excise Ruling
29 April 2004 Excise Ruling 49986 - Cooking Wines
. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The following samples were received in good order by the Laboratory and Scientific Services Directorate ("the laboratory") of the Canada Border Services Agency (CBSA), for testing of their salt and alcohol contents, and to determine whether or not they are potable: XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX The sample of XXXXX was broken at the time it was received by the laboratory, and therefore no tests could be conducted in respect of that brand. 7. The cooking wines listed above, except XXXXX were found by the laboratory to have alcohol and salt contents as indicated below: XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX XXXXX Ruling Requested You have asked that the cooking wines that are imported by your company not be treated as wine for the purposes of the Act, because they are not beverages. ...
GST/HST Interpretation
4 February 2014 GST/HST Interpretation 159039 - Eligibility of a group of corporations to file a section 156 election
. / 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 following organization structure was presented for consideration: HoldCo. / | \ / | \ / | \ US 2------- US 1 US 3 | | | | US 4 US 5 | |---------------------------------|-----------|--------------------------------- | | C 1 C 2 | | | | C 3 C 4 We were asked to assume the following regarding the above structure: * 100% ownership (number and value) of all of the voting shares of each corporation downstream in the structure by the entity immediately above it; * Hold Co. owns 100% of all of the voting shares in US2; and * US1 is a partnership with US2 and Hold Co. as its partners. ...
Excise Interpretation
13 August 2004 Excise Interpretation 52712 - Request for Prescribed Brands From Tobacco Licensee Based on XXXXX
. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'agence. ... Specifically, your request was for the following brand extensions: • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX Please note that all requests for prescribed tobacco products or prescribed cigarette formulas have to be approved by the Governor General in Council before becoming eligible for relief of the special duty and marking provisions of the Excise Act, 2001. ... Sincerely, Mark Hartigan A/Manager Excise Duty Operations- Tobacco Excise Duties and Taxes Division XXXXX XXXXX XXXXX 2004/09/08 F — RITS 52963 — Licence de tabac XXXXX ...
GST/HST Ruling
18 December 2009 GST/HST Ruling 114204 - GST Ruling on Section 150 Election between Branches
. / 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. ... STATEMENT OF FACTS Based on your letter of [mm/dd/yyyy], we understand […]: […] [information about [Foreign Co A Cdn Branch] and [Foreign Co B Cdn Branch]]. The following diagram provides a summary of the relationship between [Foreign Co A Cdn Branch] and [Foreign Co B Cdn Branch]: [Foreign Holdings Co] / \ / \ / \ [Foreign Co A] [Foreign Co B] | | | | [Foreign Country]__________________________________________________________________ | | | | [Canada] [Foreign Co A [Foreign Co B Cdn Branch] <--------- Cdn Branch] Services RULING REQUESTED You would like to know if […][Foreign Co A] and […][Foreign Co B] are entitled to make the election under section 150 of the ETA with respect to services supplied by [Foreign Co B Cdn Branch] to [Foreign Co A Cdn Branch] (and any other qualifying supply between the parties), so as to deem said supplies to be financial services. ...
GST/HST Ruling
3 May 2022 GST/HST Ruling 223567 - […][[…][Whether a Congress is a foreign convention]]
The overall planning of the Congress is organized by […] (the Society) and […]. 3. ... [yyyy] – Virtual Meeting – Total delegates was [#] (6% Canadian, […]: [94% non-residents][…]) [yyyy] – […][Meeting Held outside Canada] – Total delegates was [#] (8% Canadian, […]: [92% non-residents] […]) [yyyy] – […][Meeting Held outside Canada] – Total delegates was [#] (7% Canadian, […]: [93% non-residents] […]) According to the agenda you submitted, the first day of the Congress will have two simultaneous workshops of two hours each, two vendor workshops of one hour, an opening reception and a council and keynote speaker dinner. During the remaining [#] days, there will be [#] keynote speaker addresses […], three poster sessions […], and […][various] periods having […][multiple] simultaneous symposium/oral sessions […]. ...
Excise Ruling
13 August 2004 Excise Ruling 52583 - Excise Tax on Insurance Premiums
. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'agence. ... Specifically, your request was for the following brand extensions: • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX • XXXXX XXXXX Please note that all requests for prescribed tobacco products or prescribed cigarette formulas have to be approved by the Governor General in Council before becoming eligible for relief of the special duty and marking provisions of the Excise Act, 2001. ... Sincerely, Mark Hartigan A/Manager Excise Duty Operations- Tobacco Excise Duties and Taxes Division XXXXX XXXXX XXXXX 2004/08/13 — RITS 52712 — Request for Prescribed Brands From Tobacco Licensee Based on XXXXX ...
GST/HST Ruling
21 July 2023 GST/HST Ruling 200294 - Drop shipment of […][machinery parts]
The Agreement specifies that NonResCo is responsible for […] (the Works). ([…]) 9. ... NonResCo shall afford to […] persons lawfully upon the Site all reasonable opportunities for carrying out their work, […]. ([…]) 21. ... In addition, NonResCo shall comply with all laws, standards, codes and regulations relating to sanitation at the Site, […]. ([…]) 26. […] 27. ...
GST/HST Ruling
27 September 2011 GST/HST Ruling 131157 - GST/HST RULING - [Application of the GST/HST on the retail value of] Promotional Certificates
Upgrade [...] Facial to [...] minutes for $[...] or [...] minutes for $[...] 4. ... Receive [...]% off of any manicure and pedicure • Eye [...] Treatment and Massage: Free [...] minute eye [...] treatment, value $[...], plus free [...] ... Upgrade the massage to [...] minutes for only $ [...] or [...] minutes for only $[...] 11. ...