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GST/HST Interpretation
10 February 2014 GST/HST Interpretation 154536 - Application of section 156 to a financial institution
It owns $[…] of equipment (i.e., property) that it leases to customers. ... FinanceCo earns $[…] of exempt revenue from its loan activities and $[…] of taxable revenue from its leasing activities per year. 5. ... The value of this property, based upon book value, is $[…]. 6. It is your view that FinanceCo last manufactured, produced, acquired or imported substantially all of its equipment for consumption, use or supply exclusively (i.e., […][90% or more]) in the course of FinanceCo’s commercial activities based on the following: * property held by FinanceCo (other than financial instruments) is worth $[…]. * $[…] of that property is supplied exclusively in the course of FinanceCo’s commercial activities (leasing). * the remaining $[…] was not last manufactured, produced, acquired or imported, all or substantially all, for consumption, use or supply exclusively in the course of its commercial activities. ...
GST/HST Ruling
8 April 2016 GST/HST Ruling 158060 - Supply of professional membership to a non-resident
. / 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 We understand from your […][correspondence], the following: * You have been a non-resident of Canada since [yyyy] and are not registered for GST/HST purposes. * You carry on business, pay taxes and have been a resident of […][Country X] since [yyyy]. * [XYZ] is responsible for […][Province 1] lawyers and paralegals. […]. * You have been a member of [XYZ] since [yyyy] but you do not currently practice law in [Province 1] or elsewhere in Canada. Further, you do not provide [Province 1] law advice anywhere inside or outside of Canada. * You have maintained your membership in [XYZ] since [yyyy] as a “not in [Province 1]” member under class […]. * A professional membership in [XYZ] is required to practice law in [Province 1]. ...
GST/HST Interpretation
1 February 1996 GST/HST Interpretation 11590-3 - Are Able to Qualify as Listed Financial Institutions and Are Thus Able to Register and To Elect Under Section 150 to Exempt Supplies of Management Services From
Facts • XXXXX XXXXX[.] • XXXXX provides advisory services exclusively to its two subsidiaries; XXXXX[.] • During 1994 with respect to advisory services from the XXXXX and XXXXX[.] • The two subsidiaries are incorporated under the XXXXX and operate under the XXXXX as venture capital funds deriving their revenue from interest, dividends, fees, et cetera. • All the issued and outstanding common shares of XXXXX are owned by XXXXX[.] • XXXXX[.] • According to the XXXXX offering memorandum, investors who subscribe for one or more bonds may qualify for Canadian permanent resident status along with their spouse and dependents. Investment is required for a minimum number of years. Also according to the memorandum, the "main purpose of the Fund is to provide equity or loan capital to establish, purchase, or maintain eligible businesses or commercial ventures,..."[.] XXXXX[.] • As established in a telephone conversation with XXXXX, on August 17, 1995, XXXXX is not and has not been charging GST on its supplies of advisory services to the funds. ...
GST/HST Ruling
15 December 2020 GST/HST Ruling 203737 - Application of GST/HST to Supplies of Samosas, Pakoras, Namak Para, and Boondi
You have indicated that [the Pakoras are] […][prepared and fried x times per week]. […]. […], in a phone conversation […], it was confirmed that [the Pakoras are] […] always served hot and fresh. Furthermore, [you indicated] […] that supplies of […][the Pakoras] are always made fresh. 8. ... The appearance, taste, and texture can be compared to that of samosa pastry. 10. […] 11. ...
GST/HST Interpretation
12 January 1995 GST/HST Interpretation 11925-1[5] - Whether (Operating Under the Name ), is Entitled to Claim the Transitional Special GST Credit Available Under the Excise Tax Act (ETA) to Certified Institutions
12 January 1995 GST/HST Interpretation 11925-1[5]- Whether (Operating Under the Name), is Entitled to Claim the Transitional Special GST Credit Available Under the Excise Tax Act (ETA) to Certified Institutions Unedited CRA Tags ETA 230.2 File 11925-1 Doc. 499 Leg. ... Analysis Institutions that were certified pursuant to Part XIV of Schedule III and that are registered for the purposes of the GST are entitled to claim a special GST credit on a declining basis as follows: • 100% of the GST collectible in 1991 on the sale of specified property manufactured by handicapped individuals, • 75% in 1992, • 50% in 1993, • 25% in 1994, • 25% in 1995 and • 0% for calendar years after 1995. ... Venne Director Tax Policy- Special Sectors GST Policy and Legislation XXXXX J. ...
GST/HST Ruling
3 April 2019 GST/HST Ruling 188947 - Tax status of supplies made by a municipality
The fees and charges take into account market rates, cost recovery where possible, and any Community Charter restrictions. 5. […] [the Municipality has a] consolidated by-law to authorize the charging of fees and charges for various [Municipal] services. […] […] 6. ... Section 16 of the Community Charter authorizes officers, employees and agents of a municipality to enter, at all reasonable times, on any property to ascertain compliance with the municipality’s by-laws. 9. […] 10. […] 11. […] […] 12. ... In the case of [the Municipality], the fees are authorized by By-law […]. 21. ...
GST/HST Ruling
20 April 2021 GST/HST Ruling 197397 - AND INTERPRETATION - GST/HST on supplies related to a game
The Corporation is planning a marketing project where it would give away [#] […][prizes] […]. ... The winner has the option of choosing […][the prize] or a cash payment [the cash]. […] […][The cash] option is expected to be about $[…]. ... Yours truly, Desneiges Arbour Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate ...
GST/HST Ruling
22 May 2014 GST/HST Ruling 156633 - Application of the GST/HST to a lease of real property on which an apartment building is constructed
STATEMENT OF FACTS We understand the following from your letter and your phone message of [mm/dd/yyyy]: 1. […] (the Lessee) entered into a lease agreement (the Agreement) with […] (the Lessor) whereby the Lessee will lease certain real property (the Property) located at […]. ... Under the Agreement, the Ground Rent payment will be $[…] for the first […] years of the Term of the Agreement and will increase every […] years as indicated therein. […]. 4. ... We make specific note of the following content of the Agreement: a) Paragraph […] states that the Construction Period will begin on [mm/dd/yyyy] and end on the earlier of [mm/dd/yyyy] and the date an occupancy permit is issued by […] in respect of the Complex. b) Paragraph […] indicates that the Term of the lease is […] years which, pursuant to paragraph […], will commence on the first day after the expiry of the Construction Period (the Commencement Date). ...
GST/HST Ruling
17 December 2013 GST/HST Ruling 153989 - A "public college" pursuant to subsection 123(1) of the Excise Tax Act
. / 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. ... [Province X]. 2) The Regulations to the Letters Patent of [the Organization] include: i) [...] states that [the Organization] is a not-for-profit organization that is responsible for funding education and training that it offers; ii) [...] states that [the Organization] is recognized by the Government of [Province X] as an integral part of the post-secondary system of education in [Province X] as it offers quality training in French. iii) [...] lists [the Organization]'s objectives [...] to accomplish its mission, [the Organization] has the responsibility to: a) be self-financing. b) promote continuing education programs and general interest courses [...], training and development for the adult population of [Province X]. c) make available to adults of [Province X] continuing education programs and general interest courses, training and development. d) [...]. e) organize, administer and provide training programs focused on employment, community training and personal training, as well as continuing education programs and general interest courses. f) issue certificates specifying that the students have followed the required courses and completed all related requirements. g) work with other stakeholders in the field of education and adult learning in [Province X] and [...] for the delivery of adult education in the province. h) [...]. i) [...]. 3) [The Organization]: i) offers the following post-secondary programs leading to a certificate/diploma: bilingual administrative assistant, bilingual bookkeeper, early childhood education, human services intervention worker, resident care worker, practical nursing program, and welding, all of which require the student to have a high school diploma or equivalency as an entrance requirement; ii) offers French language training courses at various levels ([...]); iii) provides training to adults working towards obtaining their grade 12 equivalency or their grade 12 academic certificate through its various centres; iv) provides training to individuals who need to work towards writing their GED exam; and v) offers general interest courses, such as, First Aid, WHMIS, and introduction to computers. 4) [...]. 5) [...]. 6) [...] indicates that the Government (of [Province X]) recognizes [the Organization]'s services as an integral part of the post-secondary education system. 7) [...] states that the: Government (of [Province X]) wishes to recognize [the Organization] as a publicly funded educational institution. 8) [...] provides for the potential for a subsequent [...] at the expiration of the current one. ... The conditions that have been met by [the Organization] that qualifies it as a "public college" are: * it is operating a post-secondary college or post-secondary technical institute; * it receives funds from a government that are for the purpose of assisting [the Organization] with its ongoing provision of educational services to the general public; and * the primary purpose of [the Organization] is to provide programs of instruction in one or more fields of vocational, technical or general education. ...
GST/HST Interpretation
1 October 1996 GST/HST Interpretation 11680-7[4] - Application of Drop-shipment Provision to Supplies of Film Prints
1 October 1996 GST/HST Interpretation 11680-7[4]- Application of Drop-shipment Provision to Supplies of Film Prints Unedited CRA Tags ETA 179(2); ETA 179(4) Telephone #: (613) 954-8585 Fax #: (613) 990-1233 XXXXX File #: 11680-7(glr) XXXXX HQR0000124 XXXXX s. 179 ATTENTION: XXXXX I refer to XXXXX memorandum of August 7, 1996, regarding the possible application of the drop-shipment provisions in subsection 179(2) and (4) of the Excise Tax Act to supplies made by XXXXX to XXXXX. ... Jones' letters dated May 1, 1996 (File #: 11680-7(glr)), and June 6, 1996 (File #: 11680-7(glr)), on the same subject. ...