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GST/HST Ruling

29 November 2007 GST/HST Ruling 90125 - Marketing plan

Some examples of services include: •   guide or interpreter services; •   transportation services (e.g., air travel); •   sightseeing excursions; and •   ski lessons. ... The following do not qualify as services as they are property: •   short-term and camping accommodation; •   meals; •   a right to enter or attend an event, such as tickets to a show or a hockey game; •   car rentals; •   ski rentals; •   ski lift passes; •   golf green fees; and •   park passes. ... These persons are: •   a non-resident consumer; •   a non-resident non-registered tour operator; and •   a non-resident non-registered business or organization that is not a tour operator. ...
GST/HST Ruling

26 June 2014 GST/HST Ruling 157148 - Eligibility to claim input tax credits on pension plan related expenses

STATEMENT OF FACTS Our understanding of the facts based upon your submission of September 26, 2013 and our subsequent conversations […], is as follows: 1. […]. ... According to section […] of the Plan, […], all normal and reasonable expenses incurred in the operation of the Plan and all taxes levied or assessed with respect to the Pension Fund may, at the discretion of [A Co] as the Administrator, be paid from the Pension Fund. 10. […]. 11. ... An example of the discharging of such an expense for which [A Co] has contracted with [C Co] and for which you wish to claim an ITC is as follows: * Sample invoice [#] dated [mm/dd/yyyy], for the amount of $[…] plus $[…] […][GST/HST] was issued to [A Co] from [C Co], a pension consulting firm. * Work is completed by the pension consultant, [C Co]. * The invoice is sent to [A Co] for payment. * The Vice President of Human Resources reviews and approves the invoice for payment. * The Plan service provider, [B Co] is then notified that the funds can be taken from the Plan for payment. * Invoice is paid by the Plan to [C Co]. ...
GST/HST Ruling

21 December 2016 GST/HST Ruling 157873 - […][Automobile dealer] and various sales contracts

Specifically, we received the following documents: a.) your incoming letter; b.) […] (Lender 1) documents: i.) […] (the Lender 1 Dealer Agreement), […], and ii.) […] (the Lender 1 Contract); c.) […] (Lender 2) documents: i.) […] (the Lender 2 Dealer Agreement), and ii.) […] (the Lender 2 Contract); d.) […] (Lender 3) documents: i.) […] (the Lender 3 Dealer Agreement), and ii.) […] (the Lender 3 Contract); e.) […] (Lender 4) documents: i.) […] (the Lender 4 Dealer Agreement), ii.) […] (the Lender 4 Contract), and iii.) […][another contract] with similar terms as the Lender 4 Contract, and therefore not referenced in the balance of this response; f.) […] (the Lender 5 Contract); g.) […] (the Lender 6 Contract); h.) […] (the Lender 7 Contract); and, i.) […] (the Lender 8 Contract). ... The key provisions in these transactions, based on the documentation we received, are: * the contract is intended to be assigned to a lender; * upon assignment, the lender is receiving an assignment of a flow of payments provided under the contract (e.g., all amounts due now and over time); * upon assignment, the Dealer is to receive a payment based on the amount to be financed by a customer under the contract; and * the Dealer receives a fee in respect of the assignment of the contract. ... We further rule that a Fee received by the Dealer from * Lender 1 for the assignment of rights under the Lender 1 Contract, * Lender 3 for the assignment of rights under the Lender 3 Contract, or * Lender 4 for the assignment of rights under the Lender 4 Contract forms part of the consideration received for the assignment of the specific Contract, and therefore would not be subject to GST/HST as the assignment is an exempt supply. ...
Excise Interpretation

10 April 2006 Excise Interpretation 65280 - Partial Exemption of Excise Tax for Oil Drilling Businesses in Western Canada

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... Stinson & Son Ltd. (T-549-04). Nous nous excusons de notre réponse tardive. ... À mon avis, les fabricants et les importateurs peuvent se fonder sur les indications prima facies d'« utilisation projetée » par les revendeurs et par les distributeurs comme la demanderesse pour l'application du volet de la « destination de l'utilisation » et éviter d'inclure la taxe d'accise de 0,04 $ par litre vendu. » De plus, au paragraphe 29 de la décision, la Cour stipule ce qui suit: « Les deux volets du critère ne peuvent être appliqués simultanément dans une transaction entre le fabricant et un revendeur, et le revendeur devient donc responsable du paiement de la taxe d'accise si l'utilisation projetée du bien en litige lors de la revente est incompatible avec l'utilisation projetée qui a permis, à l'origine, d'exonérer la vente du paiement de la taxe d'accise de 0,04 $ par litre ». ...
GST/HST Ruling

14 April 2022 GST/HST Ruling 200481 - […][Whether zero-rated as basic groceries]

We have reviewed the website referenced in your submission, […] 5. The ingredients for the products are as follows: Product A: […]. Product B: […]. Product C: […]. Product D: […]. 6. Marketing for Product A states that it can help […]. 7. ... Marketing for Product C includes claims that the product can help […]. 11. ...
GST/HST Interpretation

4 April 2011 GST/HST Interpretation 92799 - GST/HST treatment of sale of shares and associated rights to use land

[Company B] and [...] [Company C] formed a joint venture called [...] ... Such rights, limitations and obligations are as set out in the [...], which includes Schedule [...], [...] ... You paid $[...] at the time of entering the Purchase and Sale Agreement and gave the Developer [...] post-dated cheques, each for $[...], and dated for the first day of each month beginning [mm/dd/yyyy] (i.e., the cheques totalled $[...]). ...
GST/HST Ruling

6 June 2014 GST/HST Ruling 143085 - […][Corp A] - Requirement to recapture input tax credits on loaner vehicles supplied during a repair service

The Dealership can provide a loaner vehicle for up to [#] days at $[…] per day without authorization by the DSM. ... The total claim in the amount of $[…], including HST, includes itemized charges for parts, labour and a loaner vehicle charge of $[…]; c. ... The total claim in the amount of $[…], including HST, includes itemized charges for parts, labour and a loaner vehicle charge of $[…] that was claimed under [Program X]; c. ...
GST/HST Ruling

14 October 2010 GST/HST Ruling 112685 - Application of GST/HST to XXXXX Juice

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... The Product label states: XXXXX. XXXXX. XXXXX. XXXXX. 11. The XXXXX Website states: XXXXX. XXXXX XXXXX. ... Consequently, supplies of the Product are taxable at 5% GST, or 12 %, 13% or 15% HST as applicable. ...
GST/HST Ruling

11 March 2011 GST/HST Ruling 109682 - Rate of Public Service Body Rebate

The [Professional Organization] was incorporated [...] by an Act of Parliament (the "[...] ... The [Professional Organization] sets standards for [...]. 5. In fulfilling its mandate the [Professional Organization] uses an examination process [...]. 6. [...] 7. Upon achieving a satisfactory result on the examination, the [...] receives a certificate [...]. 8. ...
GST/HST Interpretation

17 February 1997 GST/HST Interpretation HQR0000212 - Clarification As to What Constitutes a "Music Lesson" and What Constitutes a Child-care Service (Rather than a Recreational Service) Under the Excise Tax Act (ETA)

XXXXX provides the following programs: (A) XXXXX •   XXXXX[;] •   provides music appreciation and experience for children XXXXX[;] •   class meets one time per week XXXXX[.] (B) XXXXX •   provides an environment for children XXXXX in which emotional, physical, intellectual and creative experiences are offered through a combination of a play school and music program; •   XXXXX[;] •   XXXXX[.] ... Music lessons include lessons that develop skills in: •   musical performance (involving the use of the human voice or musical instruments); •   conducting an orchestra; or •   musical composition. ...

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