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GST/HST Ruling

23 June 2000 GST/HST Ruling 8278/HQR0001884 - Application of the GST/HST to Financial Services

The following services are identified in the Schedule of Services: •   XXXXX •   marketing •   XXXXX •   accounting •   financial analysis •   auditing •   information processing •   personnel, and •   investment The Agreement does not provide any details on the services listed in the Schedule. 6. In your letters, you further explain these "services" as follows: •   XXXXX •   Marketing: This means that XXXXX must actively solicit customers to XXXXX XXXXX (from XXXXX.) •   XXXXX. •   Accounting: This means that XXXXX must collect and account for XXXXX from the customers. •   Financial Analysis: This means that XXXXX must calculate the amount of the XXXXX to be paid by the customer, XXXXX[.] •   Auditing: This means that XXXXX must ensure that its intermediary service is in compliance with the agreement. ... This includes verifying that the application has been property completed and that all relevant information has been provided by the customer. •   Personnel: This means that XXXXX must provide the necessary people to actively solicit customers. 7. ...
GST/HST Interpretation

4 June 2019 GST/HST Interpretation 105471A - Supplies made by a public sector body to sponsors/endorsers

As a non-profit organization, [the Association] would also meet the definition of “public sector body” for GST/HST purposes. 2) [The Association] is a GST/HST registrant and its GST/HST number is […]. 3) [The Association] was founded in [yyyy], incorporated in [mm/yyyy], and is a member driven organization […]. 4) There are approximately [#] members, most of which are […]. ... The rest are associate members that are also involved in the […] industry, such as […], etc. 5) [The Association] holds events yearly, some of which offer sponsorship opportunities to its members. ... Bronze $[…] b. Silver $[…] c. Gold $[…] d. Diamond $[…] In exchange for sponsorship money, [the Association] provides signage with the sponsor’s name (larger consideration means a larger banner sign), print material, verbal mention at the dinner, and inclusion in the newsletter (published three times a year). ...
GST/HST Ruling

17 May 2012 GST/HST Ruling 117014 - Application of the GST/HST to various fees and reimbursed expenses

The letter also included the following documents for our consideration: * […] Corporate Structure (Flow Chart). * […] (LP Agreement). * […] (Management Agreement). * […] (Partnership Offering Memorandum). * […] (Investment Management Agreement). * […] (Fund Offering Memorandum). * […] (Service Agreement). ... Fees and reimbursement of expenses charged to […] (Advisor) 13. […] (Advisor) is a […] company incorporated on [mm/dd/yyyy], and […]. […] ([…]%) of the common shares of the Advisor are owned by the Manager. ... The Advisor is the investment manager for […] (Fund), a […] mutual fund corporation under the […] [Act]. ...
GST/HST Interpretation

1 September 2006 GST/HST Interpretation 78139 - Independent Medical Examinations and Other Independent Assessments

Fees Charged to Seller Livestock sold at auction No tax to be collected: When livestock is sold at auction on behalf of the seller, the CRA's position is that a registrant livestock auctioneer is not required to collect the GST/HST on the following charges to the seller, as they all form part of the auctioneer's service to the seller: •   selling services, including charges for: •   ear tagging; •   branding; •   pregnancy testing; •   feed; •   straw; and •   hay. Livestock not sold at auction Tax to be collected The following fees/charges invoiced to a seller for livestock that are presented for auction but not sold are subject to either the GST rate of 6% or the HST rate of 14%, as applicable: •   auctioneer's services, including charges for: •   passing charge; •   ear tagging; •   pregnancy testing; •   branding; •   feed; •   straw; and •   hay. ... Fees Charged to Buyer Tax to be collected •   branding; •   weighing; and •   feed and yardage; As previously noted, in the CRA's view, straw, hay and/or feed are usually not provided separately to a buyer. ...
GST/HST Ruling

23 December 2004 GST/HST Ruling 54536 - Supply of Three Varieties of Organic Flax Oil

XXXXX (Product A): •   Is available in a XXXXX ml container. •   Packaging states: XXXXX. •   Packaging states: XXXXX. •   Directions for use are: XXXXX. •   Ingredients are: XXXXX. •   Other ingredients listed are: XXXXX. 2. XXXXX (Product B): •   Is available in a XXXXX ml container. •   Packaging states: XXXXX. •   Packaging states: XXXXX. •   Directions for use are: XXXXX. •   Ingredients are: XXXXX. 3. XXXXX (Product C): •   Is available in a XXXXX L container. •   Packaging states: XXXXX. •   Packaging states: XXXXX. •   Directions for use are: XXXXX. •   Ingredients are: XXXXX. ...
GST/HST Ruling

10 November 2011 GST/HST Ruling 125071 - GST/HST Ruling - Application of GST/HST to franchise fees

[The] [...] (Franchisor) is one such franchise banner. The Franchisor has [...] for use in [...] a mortgage brokerage business [...]. ... Franchise only at a specific location and [...]. 5. Under [...] the Franchise Agreement, the Franchisee shall pay to the Franchisor an [...] franchise fee [...] in the amount of $[...]. ... Under [...] the Franchise Agreement, the Franchisee shall pay the Franchisor a [...] franchise fee equal to [...]% of [...]. ...
GST/HST Interpretation

9 August 1996 GST/HST Interpretation 11650-9[4] - Sale of Vehicles - The Trade-in Approach

Facts Provided: •   Value of the new vehicle: $20,000 •   Value of the trade-in vehicle: $20,000 •   Lien on the trade-in vehicle: $18,000 •   Lease payments on the new vehicle: $300/mth Department's assumptions: •   The customer is a non-registrant and the dealer is a registrant; •   Lease period on the new vehicle: 48 months •   Residual value on the leased new vehicle: $8,000 •   Money factor (interest rate): 0.0% Response requested: (i) GST charged on the monthly lease payments- 7% x ($20,000- $20,000- $8,000) / 48 months: Nil Example #3: Accommodation sale. Facts provided: •   A non-registrant vendor wishes to sell their vehicle to a non-registrant purchaser; •   The vendor sells the vehicle to a dealer as a trade-in and purchases a new vehicle from that dealer; •   The dealer sells the trade-in vehicle to the purchaser; •   Sale price of the new vehicle: $20,000 •   Value of the trade-in vehicle: $  5,000 •   Sale price of the trade-in vehicle to the purchaser: $  5,000 Department's assumption: •   The dealer is registered for the GST. ... Facts provided: •   Purchase price of the new vehicle: $20,000 •   Residual value of the old leased vehicle: $  5,000 •   Value of the old leased vehicle: $  7,000 Department's assumptions: •   The non-registrant exercises the buy-out option on the old leased vehicle; •   The registered dealership accepts a trade-in of $7,000 for the old leased vehicle. ...
GST/HST Ruling

6 May 1999 GST/HST Ruling HQR0000824 - Application of the GST/HST to the Supply of Prosthesis

The supply consists of: XXXXX XXXXX •   1 Wearables Set (1), The Set includes Support Clip (1); Shoulder Bags (2), Support Belts (2) Strain Reliefs (2) •   2 Reserve Power Pack (2), •   3 Primary Power Pack (3) •   4 Power Pack Charger (2) •   5 Power Pack Tester (1) •   6 Compact Controller (2) •   7 Implant Backup Kit XXXXX (1). ... This package includes: •   1 Personal Monitor (2), •   2 Standby Power Supply (1); •   3 Primary Power Pack (3); •   4 Reserve Power Pack (2); •   5 Power Pack Charger (2); •   6 Compact Controller (2). b) Extra Recipient In-Hospital Capability: This supply allows for the support of an additional XXXX[.] It includes: •   [1] XXXXX monitor and Cart (1); •   2 Reserve Power Pack (2); •   3 Primary Power Pack (3); •   4 Power Pack Charger (1); and •   5 Compact Controller (2). ...
GST/HST Ruling

8 October 2015 GST/HST Ruling 168474 - Psycho-Vocational Rehabilitation Assessment Services and Job Search Support Services

STATEMENT OF FACTS We understand 1. […] 2. […] 3. […] Psycho-Vocational Assessment Services 4. ... The three (3) main types of Services that may be requested by […] are: * Resume and Cover Letter Preparation * Job Search Skills * Individualized Job Placement” ii. ... Schedule B includes the following fees: * Resume and Cover Letter Preparation $[…] flat fee * Job Search Skills $[…] flat fee * Job Placement $[…] flat fee * Job Placement Extension $[…] per week * Durable Placement Fee (permanent) $[…] flat fee * Durable Placement Fee (temporary) $[…] flat fee * Service Cancellation Fee $[…] flat fee vii. ...
GST/HST Ruling

28 February 2003 GST/HST Ruling 39945 - Recovery of the Goods and Services Tax on Certain Road Construction Projects

Statement of Facts Our understanding of the facts, the transactions, and the purpose of the transactions is as follows: 1) XXXXX 2) XXXXX 3) XXXXX 4) XXXXX XXXXX ·    XXXXX ·    XXXXX ·    XXXXX-    XXXXX-    XXXXX ·    XXXXX ·    XXXXX ·    XXXXX ·    XXXXX ·    XXXXX ·    XXXXX 5) XXXXX 6) XXXXX. 7) XXXXX. 8) XXXXX. 9) At XXXXX request, the XXXXX included the construction of XXXXX work in its contract for reconstruction of XXXXX. 10) The XXXXX agreed to do XXXXX work at XXXXX cost and expense. 11) XXXXX ·    XXXXX-    XXXXX-    XXXXX ·    XXXXX ·    Upon completion of XXXXX work by the XXXXX, XXXXX will, at its cost and expense maintain the work that has been constructed under the Agreement. ...

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