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GST/HST Interpretation

10 October 2003 GST/HST Interpretation 43285 - Tax Status of the Service of Training Apprenticeship Students

Our understanding of the facts is as follows: •   The College is a public college as defined in subsection 123(1) of the Excise Tax Act (ETA). ... For periods prior to January 1, 1997, the College would have been considered a charity for purposes of the ETA. •   The XXXXX has entered into an agreement with the College to purchase apprenticeship training courses for delivery to specified third parties (apprentices) according to training standards established by the XXXXX. •   XXXXX •   XXXXX. •   XXXXX §   XXXXX §   XXXXX §   XXXXX. •   XXXXX. •   The College has filed an election under section 6 of Part III of Schedule V to the ETA to deem the supply of Apprenticeship courses to be taxable for GST/HST purposes. •   The courses provided by the College under the Apprenticeship program do not have equivalency for credit courses. •   There are situations where a student may be granted exemption for a credit course in a degree or diploma program, but this is evaluated on a case-by-case basis. ...
GST/HST Interpretation

23 April 2009 GST/HST Interpretation 114039 - Valeur de l'importation temporaire d'un aéronef loué

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Nous comprenons que: XXXXX. (le " preneur ") a conclu une entente pour louer l'aéronef suivant de XXXXX (le " bailleur "), un non-résident avec qui le preneur n'a aucun lien de dépendance. Type d'aéronef Numéro du modèle Numéro de série Immatriculation XXXXX XXXXX XXXXX XXXXX Le contrat de location commence le XXXXX et se termine le XXXXX. L'aéronef sera importé à XXXXX au plus tard le XXXXX et sera exporté le XXXXX. Au terme d'un bail conclu avec le bailleur, le preneur ne doit pas détenir l'aéronef au Canada pendant plus de 24 mois. ...
GST/HST Ruling

3 August 2021 GST/HST Ruling 211272 - Assignment of a right to purchase a residential condominium unit

According to the APS: a) the Assignor was required to pay, to the Vendor, a purchase price in the amount of $[…] for the Unit; […][GST/HST] was not included in the price. b) the Assignor was required to pay, to the Vendor, a total deposit amount of $[…] in four installments: (i) Initial: $[…] (that is, [#]% of the purchase price) due at the time the APS is accepted by the Vendor; (ii) Second: $[…] (that is, [#]% of the purchase price) due on the later of [mm/dd/yyyy] and the [#] business day after the delivery of a document entitled Amendment to the Purchaser; (iii) Third: $[…] (that is, [#]% of the purchase price) due on [mm/dd/yyyy]; and (iv) Fourth: $[…] (that is, [#]% of the purchase price) due on [mm/dd/yyyy]. c) the Assignor was required to pay, to the Vendor, the balance of the purchase price (presumably, $[…], subject to closing adjustments including [GST/HST]) on the closing date. 6. The total deposit amount (that is, $[…]) was paid by the Assignor. 7. ... According to the Assignment Agreement, the Assignor’s Statement of adjustments and the Assignor’s signed direction to […](the Assignor’s legal representative) entitled “Order to pay”: a) the Assignee was required to pay, to the Assignor, an assignment amount of $[…] for the assignment of his rights in the APS. $[…] was payable as a deposit and the remaining balance of $[…] was payable to the assignee’s solicitor within [#] business days of receiving the fully executed assignment contract signed by the Vendor, and to the assignor’s solicitor within [#] business days of receiving the fully executed assignment contract signed by the Vendor; b) the assignment amount included an amount to reimburse the Assignor for the Deposit of $[…] that was paid according to the APS, thus the Assignor’s profit before assignment fees and commissions was $[…]; c) the Assignor was required to pay, to the Vendor, an assignment and filing fee totalling $[…]; d) the Assignor was responsible for paying real estate commission to both the listing and selling agents in respect of the assignment of the Assignor’s rights in the APS, which was a total of $[…]; e) the Assignor’s accountancy fees, $[…], and legal fees and related disbursements, estimated to be $[…], totalled $[…]; f) the Assignor’s loss after fees and commissions was $[…]; and g) the assignment amount (that is, $[…]) was inclusive of any [GST/HST] payable with respect to the assignment of the Assignor’s rights in the APS, and the Assignor must remit any [GST/HST] payable. 13. ...
GST/HST Interpretation

26 June 1998 GST/HST Interpretation HQR0001098 - GST/HST Status of Kindergarten Fees

The tuition fee for preschool, junior kindergarten and kindergarten programs are as follows: Full day students XXXXX per month / 5 days XXXXX per month / 3 days XXXXX per month / 2 days [i] * Half day students XXXXX per month / 5 half days XXXXX per month / 3 half days XXXXX per month / 2 half days 11. ... What is the GST status of tuition fees for the following:  •  grades 1, 2 and 3;  •  kindergarten;  •  junior kindergarten; and  •  preschool. 2. ... Tuition fees for the following are exempt:  •  grades 1, 2 and 3;  •  kindergarten;  •  junior kindergarten; and  •  preschool. 2. ...
GST/HST Interpretation

18 September 2012 GST/HST Interpretation 143223 - Option to claim a provincial public service bodies’ rebate or a provincial new residential rental property rebate for new housing

. / 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. ... In [mm/yyyy], [the Organization] purchased [#] residential condominium units (collectively referred to hereafter as “the Units”) for $[…] plus $[…] HST from […] (“the Developer”), the registered owner of the newly constructed condominium complex in which the Units are situated. According to the Buyer Statement of Adjustments provided for our review, the Units are legally described as Strata Lots […]. […] […][A question is] whether [the Organization] was similarly precluded from claiming the British Columbia new residential rental property rebate in respect of the provincial portion of the HST payable in light of its eligibility for a British Columbia public service bodies’ rebate (albeit for a lesser amount) in respect of that tax. […]. ...
GST/HST Ruling

24 October 2012 GST/HST Ruling 94993 - The application of GST/HST to real estate valuations

. / 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 * Your company occasionally supplies real estate valuations for insurance claims. * You supplied two fire insurance reports to us as samples of your work: 1) […][Address in Canada], produced for […] and 2) […][Address in Canada], for […]. * The report for the first case stated at page [#]: “Property inspection –... ... In this particular situation valuation services that concern property insurance claims the service would be exempt under the definition of financial service in subsection 123(1) if it complied with paragraph (j.1) of that definition and was not excluded by paragraph (r). ...
GST/HST Ruling

31 August 2012 GST/HST Ruling 143522r - Supply of Bottled Juice

Both products are sold in [#] ml bottles that are sealed […]. 3. […] [weight of raw fruit used in production]. 4. Bottle labelling suggests individuals […] [suggested serving size] 5. ... RULING REQUESTED You would like to know if the supply of your […] juice blends, in [#] ml bottles, is subject to GST/HST. ...
GST/HST Ruling

13 July 2020 GST/HST Ruling 198971 - Input tax credit entitlements related to […][the Program]

The purpose of the Corporation is […] 3. The members of the Corporation are: […][Member #1], […]. 4. ... [Member #1] registered for GST/HST purposes on [mm/dd/yyyy]. 14. […]. 15. ... Yours truly, Desneiges Arbour Charities and Non-profit Organizations Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 […]. 2 […]. 3 […].     ...
GST/HST Interpretation

12 August 2005 GST/HST Interpretation 56852 - Eligibility for input tax credit for GST paid on purchase of a truck

The following information has been provided in your letters, from the web-sites of XXXXX and during our telephone conversations XXXXX: •   XXXXX. •   The XXXXX receives funding from the XXXXX. •   The office of the XXXXX is not located on a reserve. •   XXXXX. •   The members of the XXXXX are elected and are responsible for their operating budget XXXXX. •   For the year XXXXX a motion was passed by the XXXXX designating the office of XXXXX as the finance and administration unit in charge of budgets, accounting, supporting document retention, monthly financial statements, etc. •   The XXXXX is incorporated under the Laws of Ontario as a corporation XXXXX. •   The XXXXX is overseen by a Board of Directors representing the XXXXX. •   The objective of the XXXXX. •   The office of the XXXXX is not located on a reserve. XXXXX. •   The XXXXX elects the directors of the XXXXX from the members of the XXXXX. ... Chesterman Aboriginal Affairs Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate 2005/06/30 RITS 57840 Supplies to Partnership ...
GST/HST Ruling

18 January 2013 GST/HST Ruling 148702 - Sale of interest in family cottage

At the time of purchase, the Property was a vacant lake-front parcel of land, […] feet wide and […] feet deep. ... You took out building permits and built a […] square foot cottage on the Property in [yyyy]. ... Yours truly, Eric Paraskake Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate     ...

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