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GST/HST Interpretation
18 August 2008 GST/HST Interpretation 44960R - Application of GST/HST to an Independent Sales Contractor of a Direct Seller
XXXXX. • XXXXX. • XXXXX. • XXXXX revenue comes from both XXXXX and XXXXX within XXXXX. • XXXXX is a non-resident organization that is not registered for GST/HST. • Through XXXXX, you purchase XXXXX exclusive products for your own use, sell products to customers and XXXXX. • XXXXX sells various XXXXX materials to XXXXX ISCs. ... The CDs you provided are: XXXXX. • XXXXX. • XXXXX is a voice, fax and e-mail messaging system used by some XXXXX pay a monthly fee for the service. • ISCs can subscribe to the XXXXX Web site for a monthly fee. ... The payments are calculated as follows: XXXXX. × XXXXX. • XXXXX. • XXXXX holds XXXXX meetings in hotel conference rooms for the purpose of showing the XXXXX to new prospects that its XXXXX ISCs bring to the meetings. ...
GST/HST Interpretation
1 March 1996 GST/HST Interpretation 11895-1[9] - Payment of Patronage Dividends
1 March 1996 GST/HST Interpretation 11895-1[9]- Payment of Patronage Dividends Unedited CRA Tags ETA Sch V, Part VI, 28; ETA 141(1) File: 11895-1(on) c.n. 1403(REG) Sch. V/VI/28 & ss. 141(1) XXXXX March 1996 Subject: XXXXX (the Commission) I refer to the E-Mail of November 28, 1994, from XXXXX of your office addressed to Mr. ...
GST/HST Interpretation
8 June 1995 GST/HST Interpretation 11865-2/39 - The Supply of a Health Care Service Made by an Ophthalmologist
Analysis- Health Care Services Based on the information provided there appears to be some confusion regarding the use and meaning of the terms " XXXXX ", "cost of using facilities", "facility fee/charge" and "management fees". ... For example, during periods of vacation, illness or maternity leave, a replacement medical practitioner known as a " XXXXX " may replace an established practitioner. ... In this case the medical practitioner using the facilities owned by the partnership is not providing a " XXXXX ", but is rather an associate or self-employed practitioner, hence, paragraph 30(c) of GST Memorandum 300-4-2 is not applicable. ...
GST/HST Interpretation
30 August 2004 GST/HST Interpretation 42363 - Treatment of Leasehold Improvements by the Tenant where their Cost is Greater than the Leasehold Allowances Provided By the Landlord
X does not carry on business in Canada for GST/HST purposes. • X owns XXXXX% of the shares of A. ... The factors that will be considered in determining whether a non-resident person is carrying on business in Canada for GST/HST purposes 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; • the place from which transactions are solicited; • the location of 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, Patrick McKinnon Manager Border Issues Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate 2004/07/29 — RITS 43263 — Sections 201 and 235 of the Excise Tax Act ...
GST/HST Interpretation
12 June 2007 GST/HST Interpretation 85568 - Municipal Designation
Statement of Facts Our understanding of the facts is as follows: • The Product comes in XXXXX-gram re-sealable pouches. • The Product is available in XXXXX varieties: XXXXX. XXXXX. • The Product packaging indicates an expiry date and that XXXXX. • There is no XXXXX added to the Product. • The Product label states: XXXXX. • The Product is placed near XXXXX in grocery stores. • Each variety has XXXXX listed on its' packaging. ... Snack mixtures usually have the following characteristics: • Consumers commonly view them as snacks. • Their ingredients are ready to eat; no further processing is required. • The ingredients have been combined before the product is sold. • The main ingredients remain separate and distinct from each other and are not bound into one whole. • The main ingredients are often coated with a savoury seasoning such as salt or barbecue flavouring. • They are eaten by the handful or as individual bite-sized pieces without utensils. • They are usually sold in pouch packs or bags, from bulk bins or in clear plastic containers. ...
GST/HST Interpretation
1 March 1996 GST/HST Interpretation 11895-1[10] - Supplies Made by the (the Commission)
1 March 1996 GST/HST Interpretation 11895-1[10]- Supplies Made by the (the Commission) Unedited CRA Tags ETA Sch V, Part VI, 20(h) File #: 11895-1(on) Case No. 1511(REG) Sch V/VI/20(h) XXXXX March 1996 I refer to the letter of September 28, 1995, from XXXXX of your office, sent by facsimile to the General Applications Unit of GST Rulings and Interpretations. ... Under XXXXX, the Commission is mandated to: • manage the tender process for the collection of refuse within the Region; • administer the purchase or lease/purchase of refuse carts and supplementary equipment; • administer the distribution of refuse carts to householders within the Region; • determine the annual charge required for providing a refuse collection system; and • promote the waste watch program jointly with the XXXXX[.] 4. ...
GST/HST Interpretation
23 January 2013 GST/HST Interpretation 132321 - Ballet Lessons
. / 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. [Addressee] Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5 Case Number: 132321 January 23, 2013 Dear [Client]: Subject: GST/HST INTERPRETATION Ballet Lessons Thank you for your letter of [mm/dd/yyyy], concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to ballet lessons. ... The CRA does not consider the following courses to develop or enhance a student's occupational skills: • sports • games • hobbies; or • other recreational or cultural pursuits, that are designed for personal interest. ...
GST/HST Interpretation
19 July 2011 GST/HST Interpretation 111922 - Third party administrative services
. / 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 your letter, excerpts from Corporation X's [...] (Duties) attached to the letter, and your fax which includes a sample [...] ... In accordance with your letter, the Duties and the Notice, Corporation X performs the following activities for the Providers and Employers in order to provide the Administrative Services: • maintains employee eligibility files; • prepares monthly employee benefit billings; • collects and accounts for the premiums from those billings; • remits premiums to various insurers; • performs accounting for premiums and prepares monthly premium statements; • processes claims and administers renewals and benefit changes; • prepares updates of member information; • updates and balances pre-authorized chequing payments for electronic transmission; • processes month-end reports; • produces employee wallet certificates and distributes [...] cards; • maintains records with respect to the administration of the employee plans; and • provides client support and clerical duties. ...
GST/HST Interpretation
24 September 2010 GST/HST Interpretation 107633 - Tax Status of School Bus Transportation
It further provides that the transportation consortium will manage and administer all home-to-school-to-home transportation, school-to-school transportation, and special needs transportation within the Boards' jurisdiction. d) Subparagraph [...] requires the transportation consortium to enter into common contracts with transportation service providers. e) Paragraphs [...] provide for the supervision of the transportation consortium by a management committee (CMC). [...]. The day to day management of the transportation consortium would be provided by a General Manager. [...]. f) Paragraph [...] mandates the transfer of each Board's transportation staff to the transportation consortium. [...]. g) Paragraph [...] provides that the costs associated with the management of the affairs of the transportation consortium and the cost responsibilities of each Board shall be as set out in Schedule [...]. h) Paragraph [...] confirms that the transportation consortium shall provide transportation services in accordance with the Boards' transportation policies. ... It further provides that [...]. l) The remainder of Schedule [...] to the agreement sets out the formulae to be used to calculate each Board's share of the management, administration and transportation costs of the transportation consortium. m) Schedule [...] to the agreement describes the make up, roles and responsibilities of the CMC. n) Schedule [...] to the agreement sets out the roles and responsibilities of the General Manager. o) Schedule [...] to the agreement provides some specific duties of the General Manager including: [...]. p) Schedule [...] to the agreement describes the mediation and arbitration procedures to resolve any dispute which arises between the Boards. q) [...] is a graphic entitled [...]. 5. ...
GST/HST Interpretation
11 October 2001 GST/HST Interpretation 32220 - Fourniture de services par
Si le service est fourni à un résident, les frais de mandataire sont taxables au taux de 7 %, ou au taux de 15 % si la fourniture est effectuée dans une province participante. Si le service est fourni à un non-résident, ces frais peuvent être détaxés (taxés au taux de 0 %) conformément à l'article 5 de la partie V de l'annexe VI de la Loi sur la taxe d'accise (ci-après appelée " la Loi "). ... Les débours qui se rattachent à une fourniture taxable au taux de 7 % ou de 15 % sont taxables au taux de 7 % ou de 15 % respectivement. ...