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GST/HST Interpretation

17 January 2011 GST/HST Interpretation 125334 - Application of the GST/HST to certain services provided by automobile dealers

The employees of the dealership perform the following activities: obtaining the credit information from the customer; completing a loan application form; explaining to the customer the different loan terms and interest rates available; helping the customer select the type of loan which best suits the customer's needs; determining the interest rate and payment stream; and screening and verifying the loan application, making a recommendation on acceptance or rejection of the application and forwarding it for final approval to the financial institution which will grant the credit. ... In offering a loan, the automobile dealer must negotiate a number of different financing variables with the customer, such as: amount to be financed; term; down payment; security deposit; addition/reduction of accessories or ancillary products (e.g. supplementary warranties); a co-buyer to support the credit risk; and co-guarantor to support the credit risk. As the automobile dealer negotiates the terms and conditions of a loan with a customer, the automobile dealer is always cognisant of the quality criteria required by its various potential assignees. If an automobile dealer hopes to eventually assign a loan to an assignee, the automobile dealer will generally submit the loan application to the assignee in advance. ... Among the most common examples, the potential assignee can choose to pay: a fixed amount for its purchase of the loan; an amount calculated on a percentage of the sum financed; nothing- example where the auto manufacturer decides to subsidize the rate of interest paid by the customer; at a premium or discount to the face amount based on the assignee using a different interest rate target than the loan rate. At any particular time, an automobile dealer can find out from different potential assignees what they may be willing to offer in terms of accepting assignment of a loan. ...
GST/HST Ruling

21 July 2016 GST/HST Ruling 173103r - Relief of the GST/HST available to Indian bands on surveying services of settlement lands

STATEMENT OF FACTS The following information was provided in your [correspondence]. 1. […]. 2. […]. 3. ... According to your letter, the Settlement Agreement provides, […], for the following: […] 9. ... The scope of the survey work to be undertaken by [Survey Company X] includes the following: […][information on activities and land to be surveyed] Drafting numerous reference plans involving […] computer-aided design (CAD) drafting time. 11. ...
Excise Interpretation

29 August 2007 Excise Interpretation 92686 - Requirement to be licensed

(C) IMPORTED CIGARS- CALCULATION OF ADDITIONAL DUTY The additional duty on imported cigars is calculated as the greater of: •   $0.066 per cigar, and •   66%, computed on the "duty-paid value". For purposes of determining the additional duty on imported cigars, the Act provides that the term "duty-paid value" for imported cigars means: •   the value of the cigars for purposes of the duty (Whether or not the cigars are subject to duty) (calculated as a % of value) under the Customs Act, plus •   $16.60 per 1,000 cigars, plus •   Customs duty; plus •   the value of the cigar container. ... Yours truly, Douglas Wood, BComm, CGA Rulings Officer Excise Duty Operations- Tobacco Unit Excise Duties & Taxes Division Excise and GST/HST Rulings Directorate 2007/07/05 RITS 94747 Canadian Whisky and Excise Duty ...
GST/HST Ruling

8 January 2007 GST/HST Ruling 81915 - Tax Status of Real Estate Commissions

Statement of Facts Our understanding of the facts based on your letter and our subsequent telephone discussions is as follows: •   XXXXX is a non-resident vendor of goods based in XXXXX, US. •   XXXXX acquires the goods on a delivered in Canada basis from XXXXX, a GST/HST registered non-resident company. •   The goods acquired by XXXXX are manufactured and packaged in XXXXX US. by XXXXX and delivered to XXXXX on a FOB XXXXX basis. •   XXXXX has contracted with XXXXX to store the goods until they are sold. •   XXXXX has XXXXX Canadian clients for the goods XXXXX. ... The factors to consider in determining whether, for GST/HST purposes, a non-resident person is carrying on business in Canada in a particular situation include: •   the place where agents or employees of the non-resident are located; •   the place of delivery; •   the place of payment; •   the place where purchases are made or assets are acquired; •   the place from which transactions are solicited; •   the location of assets or an inventory of goods; •   the place where the business contracts are made; •   the location of a bank account; •   the place where the non-resident's name and business are listed in a directory; •   the location of a branch or office; •   the place where the service is performed, and •   the place of manufacture or production. ... Yours truly, Jeff Frobel Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2007/01/10 RITS 82341 Eligibility to Claim Input Tax Credits (ITCs) in Respect of Hedging Activities ...
Excise Interpretation

25 November 2010 Excise Interpretation 125326 - Authorised insurer placements via non-resident intermediaries

. / 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. ... Interpretation Requested You would like to know if the activities listed below, if undertaken by any one of your Canadian network offices on a global policy covering Canadian risks, would be sufficient to enable them to be viewed as the broker through whom insurance contracts are entered into or renewed for Excise Tax purposes. Collecting insured data; Developing program strategy/design; Advising on local legal, regulatory and insurance practices; Producing policy wordings; Presenting proposal/terms to the insured; Issuance of documents; Invoicing of local premium; and Local tax settlement. ...
GST/HST Interpretation

30 May 2011 GST/HST Interpretation 85885 - GST/HST treatment of trailer park site rental

The Park is located [...] in the municipality of [...] [Participating Province X]. ... It has a total of [...] sites. [...] of the sites are for transient campers. ... For example, the unit on Lot [...] is described as [...]. Sale prices for these units range from $[...] to $[...]. ...
GST/HST Ruling

13 January 2015 GST/HST Ruling 162497 - FCTIP - Tour Package Eligibility

Tour 1 includes between [#] and [#] nights of accommodation in Canada. ... Tour 2 includes between [#] and [#] nights of accommodation in Canada. ... Tour 3 includes between [#] and [#] nights of accommodation in Canada. ...
GST/HST Ruling

16 April 2019 GST/HST Ruling 179050 - GST/HST status of […][Brand] Granola products

The ingredients of the three […][mixes] are as follows: i) […][Mix 1] Rolled oats, […][ingredients] ii) […][Mix 2] Rolled oats, […][ingredients] iii) […][Mix 3] Rolled oats, […][ingredients]. 5. The Producer’s website[…][indicates] [Mix 1] […][goes] with yogurt and fruits, [Mix 2] […][goes] with milk or yogurt and […], and [Mix 3] […][can be used] for breakfast […]. 6. The Products are contained loose in a pouch/bag containing […] grams, […] grams or […] kilograms. 7. ...
GST/HST Ruling

3 July 2012 GST/HST Ruling 109082 - Eligibility to claim the 83% Public Service Body Rebate as a facility operator

Residents at the Facility have various health care conditions including Parkinson’s disease, cancer, acquired brain injuries, MS, or are post-stroke. […] percent ([…]%) of residents ([#]) are incontinent; […] percent ([…]%) of residents ([#]) experience a form of dementia or related cognitive impairments. […] 10. ... Appendix […] to the agreement reads as follows: […] 12. The physicians each work […] hours a week and will visit residents under their care at least […]. ... Residents at the Facility receive physiotherapy […] and […] dietary services […]. ...
GST/HST Ruling

14 August 2006 GST/HST Ruling 81097 - Application of GST/HST on XXXXX in the form of XXXXX

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Statement of Facts •   XXXXX. •   The Company is a Canadian tour operator who resells XXXXX blocks of hotel rooms XXXXX to non-registrant non-resident tour operators XXXXX. •   XXXXX. •   After, July 1, 2006, the Company received an invoice from the hotel for short-term accommodation and was charged GST at 6%. •   XXXXX. ... Yours truly, Michèle Routhier, CMA Technical Analyst Services and Intangibles Unit General Operations & Border Issues Division Excise and GST/HST Rulings Directorate 2006/07/28 RITS 81356 Application of GST/HST to Cemetery Products and Services ...

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