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GST/HST Ruling

17 March 2016 GST/HST Ruling 170841 - Application of GST/HST to coconut based beverages

STATEMENT OF FACTS We understand the facts as follows: 1. […], […] (the Company), manufactures and sells 3 coconut based beverage products (the Products) […]: a. […] (Product A); b. […] (Product B); and c. […] (Product C). 2. ... The Products include […][list of ingredients]. […]. 5. […] coconut cream is used as the base in the Products. 6. Product A has […]% natural coconut cream by volume. 7. Product B has […]% natural coconut cream by volume. 8. ...
GST/HST Ruling

25 January 2013 GST/HST Ruling 140259 - Application of the GST/HST to sponsorship revenue and advertising services

The [agreement] can be summarized as follows: […] [Describes the obligations of the Association and the Sponsor] […] [Describes the general provisions of the agreement] […] [Identifies which province's laws govern the agreement] 5. ... The sponsor is referred to in the agreement as "[…]". The terms of the sample agreement provides as follows: […] 7. ... Yours truly, Heather Reardon Charities, Non-profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate     ...
GST/HST Interpretation

18 March 2019 GST/HST Interpretation 186839 - Personnes morales étroitement liées

Faits Selon l'information contenue dans votre [correspondance], dans […] (la « Convention Unanime ») en date du [jj/mm/aaaa] et dans […] (la « Convention des Actionnaires ») en date du [jj/mm/aaaa], notre compréhension des faits est la suivante: 1. […] (collectivement appelés les « Actionnaires ») sont chacun propriétaire de moins de 90% du capital-actions de […] (la Société). ... La Société a des filiales (les « Filiales ») dont chacune est la propriété exclusive de la Société. 3. ... La Convention Unanime a été conclue conformément à l’article […] de la Loi sur les sociétés par actions au Québec qui prévoit: […] 7. ...
GST/HST Ruling

5 August 2014 GST/HST Ruling 162970 - Tax Status of […][the Product]

The Product is new and has been launched in […] but not yet in Canada. 4. […]. 5. A sample of the Product, in the […] flavour, […], has been provided. 6. ... It comes in [#] different flavours: […][list of flavours]. * Taste: The Product tastes very much like the […] potato chips. * Texture: The Product is thin, light, puffed, and dry. ...
GST/HST Ruling

29 June 2018 GST/HST Ruling 125593r - Municipal wastewater discharge services

Specifically, the […] locations referred to above include: […] 5. […][Additional information from the report] 6. ... Accordingly, the municipalities operate on a basis of understanding and cooperation as the supplies have been ongoing since the expiry of the previous formal agreement. 7. […] 8. […] 9. […] states that a draft Agreement has been developed between the City and [XYZ] and outlines some of the key points as follows: a. […]; b. […]; c. […]; d. ... Invoices for the receipt and treatment of these wastewater […] will be prepared quarterly […] 10. […]. ...
GST/HST Interpretation

28 October 2016 GST/HST Interpretation 152996 - Application of GST/HST to Executor and Attorneyship Fees

X]. […] [Executor A’s] GST/HST account […] status […][is] currently “active”, […][Executor A’s] filing status is “non-filing”, and [Executor A’s] reporting period [is] “non-reporting”. […] [Executor A’s] business activity […][is reported] to be […]. 2. ... The Estate paid an Attorneyship fee of $[…] to [Executor A] […][around that same date and] remitted an amount of $[…] as HST directly to the Receiver General, by way of a bank draft ([…]). 5. ... The CRA deposited both of the above mentioned bank drafts on [mm/dd/yyyy], and the payments were posted to an account number […]. 7. […], the CRA received a completed General Application for Rebate of GST/HST (GST189) […] requesting a rebate of tax paid in error for a total of $[…] in respect of the […][amounts] remitted by the Estate as tax in respect of [Executor A's] Attorneyship fees [and] […] Executorship fees. 8. […]. 9. […]. 10. […]. 11. […][Subsequently], the Estate requested that the amount of the rebate request be increased to include also the $[…] remitted directly by the Estate as HST in respect of the Executorship fees paid to [Executor B], [thereby] increasing the rebate requested to $[…]. 12. ...
GST/HST Ruling

19 July 2011 GST/HST Ruling 125864 - Application of GST/HST to Profit Share Payments

Subparagraph [...] of the Agreement provides that the Bank will be entitled to a quarterly [...] ... Where the [...] is [...] the Bank will pay the [...] re-payment to the Insurer. 10. ... Pursuant to section [...] of the Agreement, the Insurer will also be paying the Bank a [...]. ...
GST/HST Ruling

17 January 2013 GST/HST Ruling 119144 - Rebate for printed books under section 259.1 of the Excise Tax Act

[Addressee] Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5   Case Number: 119144   Business Number: […]   January 17, 2013 Dear [Client]: Subject: GST/HST RULING Rebate for printed books under section 259.1 of the Excise Tax Act Thank you for your letter of October 26, 2009, concerning the eligibility of […] (the Church) to claim a rebate for printed books pursuant to section 259.1 of the Excise Tax Act (ETA). ... The library is open to the congregation of the Church and members of the general public on [dd] and [dd] between the hours of […] and […]. ... Yours truly, Trent MacDonald Charities and Non-Profit Organizations Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate     ...
GST/HST Interpretation

17 December 2015 GST/HST Interpretation 153009 - […][Whether a zero-rated supply of a Financial Service to a non-resident shareholder]

[Addressee] FILE: 153009 [Dear Client:] SUBJECT : [GST/HST INTERPRETATION] […][Whether a zero-rated supply of a Financial Service to a non-resident shareholder] This […][is about] whether […] (the Corporation) is making a zero-rated supply of a financial service to its non-resident shareholders. […]. […] […][The incoming submission] includes the […] analysis of various issues surrounding specific activities undertaken by the Corporation which relate to […] a zero--rated supply of a financial service being made by the Corporation to its shareholders. ... [The submission] suggests that this would arise with regard to the ongoing claim that the shareholders have against the Corporation as would be the case in a liquidation of the Corporation; and, 3) paragraph (b): * the operation or maintenance of (an) account. ... If […] the Corporation is a “financial institution”, this section may zero-rate an otherwise exempt supply of a financial service, provided the supply is not excluded by paragraphs (a) to (e) of section 1, or by section 2, of Part IX of Schedule VI. […] If you require clarification with respect to any of the issues discussed […], please call me directly at 604-658-8526. ...
GST/HST Ruling

15 July 2005 GST/HST Ruling 59548 - Application of GST/HST to Cranberry Juice

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... We provide the following in response to your questions: 1 & 2. Depending on the facts of a particular situation, it may appear that there is an advantage when a significant portion of a tour package is short-term accommodation. ... Yours truly, Alyson Trattner Manager, Services and Intangibles Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate APPENDIX A- Tour Package elements: Short-term accommodation $ 930.00 Tour package purchased * $ 1,200.00 GST on accommodation 65.10 GST on tour package 84.00 less: Rebate (100% of GST paid) 65.10 less: Rebate (50% of GST paid on package) 42.00 Non-registered, non-resident tour operator's cost to operator's cost to acquire element acquire element forms part of the larger Tour Package Tour package includes short-term accommodation at a hotel or resort $ 930.00 Non-registered, non-resident tour $ 1,242.00 Supply made by a non-registered, non-resident tour operator (NR/NR) to a non-resident Operator's selling price $ 2,598.00 20% mark-up on cost ($930 + $1,200) GST not applicable- plus GST not rebated ($42)  ------------- Operator's revenue $ 2,598.00 Operator's revenue $ 2,598.00 less: Short-term accommodation 930.00 less: Tour package 1,242.00 includes GST paid and not rebated ($42)  -------------- Net amount $ 426.00 (before other expenses) Registered tour operator's amount charged to customer Operator's revenue (consideration) $ 2,510.15 GST 175.71 less: Rebate 87.86  ------------- $ 2,598.00 amount the same as the NR/NR's selling price Supply made by a registered tour operator to a non-resident Operator's revenue (consideration) $ 2,510.15 less: Short-term accommodation 930.00 registered tour operator entitled to claim ITC for GST less: Tour package 1,200.00 registered tour operator entitled to claim ITC for GST  ------------ Net amount $ 380.15 (before other expenses) 2005/07/25 RITS 60361 Monitoring Services ...

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