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GST/HST Interpretation
23 November 2016 GST/HST Interpretation 165129 - ITC eligibility for company that owns trust units
. / 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] Based on the […] information provided […], we understand the following: * The Parent is the parent corporation of a complex structure of entities, […]. The Parent owns units of […][Trusts] […]. * […][Information about specific transactions] * […][Specific information about the organizational structure] * We understand that […][the supply of real property to other entities] is a commercial activity for GST/HST purposes. * The […][argument has been made] that [the Parent] provides management services to related entities, and has provided sample invoices which indicate that it provides management services to […][X], however, we have not been provided with any agreements for management services. ...
GST/HST Interpretation
26 September 1996 GST/HST Interpretation 11820-3[1] - Amendments to the Visitor Rebate Program
26 September 1996 GST/HST Interpretation 11820-3[1]- Amendments to the Visitor Rebate Program Unedited CRA Tags ETA 252.2 Telephone #: (613) 954-5124 Fax #: (613) 990-1233 11820-3 (crl) s. 252.2 September 26, 1996 XXXXX ATTENTION: XXXXX I am in receipt of your letter dated August 21, 1996, in which you voiced your opinion concerning the amendments to the visitor rebate program. ...
GST/HST Interpretation
25 July 2014 GST/HST Interpretation 158278 - Election under section 167 - Eligibility when real property is leased
You have asked […], whether the parties are eligible to use the election under section 167 of the Excise Tax Act specifically in one of the […] situations, details of which are described below. ... As consideration for the rights granted under the Franchise Agreement, the agreement requires an initial franchise fee of $[…] and royalty fees of […]% of gross sales. ... Consideration for this property and service is payable as [#] installments of $[…] plus any balance due. ...
GST/HST Interpretation
2 April 1996 GST/HST Interpretation 11645-1[3] - Importation of
2 April 1996 GST/HST Interpretation 11645-1[3]- Importation of Unedited CRA Tags ETA 169(1); ETA 212 File #: 11645-1 (gp) ss. 169(1), 212 XXXXX April 2, 1996 Dear Mr. ... The following information was provided in your memorandum and in a subsequent telephone conversation with Gwen Preston of my staff: • XXXXX[.] • XXXXX receives an order for a XXXXX from a XXXXX dealer in Canada and installs the kit into a XXXXX[.] • When the van conversion is complete, XXXXX ships the van to the dealer and invoices the dealer for the kit and the installation. • At time of importation, XXXXX pays the duties and GST on the van, including the value of the kit with the entry for the van. ... Jones Director General Applications Division GST Rulings and Interpretations Directorate Policy and Legislation Branch GAD # 2823 (GEN) c.c.: R. ...
GST/HST Interpretation
18 June 1997 GST/HST Interpretation HQR0000527[2] - Application of the GST to Supplies of Admissions to Annual Conventions
18 June 1997 GST/HST Interpretation HQR0000527[2]- Application of the GST to Supplies of Admissions to Annual Conventions Unedited CRA Tags ETA 123(1) admission; ETA 222(1); ETA 240(1) Telephone #: (613) 954-5124 Fax #: (613) 990-1233 11690-1(crl) HQR0000527 ss. 123(1), 222(1), 240(1) XXXXX June 18, 1997 This is refers to your facsimile dated January 27, 1997, in which you requested information concerning the registration status of the XXXXX with respect to a convention which was held in Canada in XXXXX[.] Statement of Facts • The District, a resident of Canada, was not (and is not currently) registered for the Goods and Services Tax (GST). • The District holds a convention on an annual basis, hosted by a club in either Canada XXXXX. ... A registration form was subsequently submitted to the Department. • When no reply was received, XXXXX contacted the Tax Services Office (TSO) and requested a ruling in regard to the convention. • XXXXX was advised that the District should charge the GST and a provisional GST registration number was assigned to the District. • The District collected the GST on the convention and the GST was recorded in the accounts, by the auditor. • The TSO sent a letter to the District stating that it was not required to register but neither an explanation nor a ruling accompanied the letter. ...
GST/HST Interpretation
18 April 2011 GST/HST Interpretation 127267 - GST/HST on Painting of Parts
[(the Company)] by [...] a painting service provider located in [...] ... In this case, the Company ships parts from their plant in [...] [City 1, Province X] (a non-harmonized province) to [...] (the "service provider"), a sub-contractor in [Province Y] (a harmonized province), for a painting process as described in Company purchase order #[...] and #[...] and service provider invoice #[...]. ...
GST/HST Interpretation
27 July 2012 GST/HST Interpretation 126511 - GST/HST Treatment of Retail Display Allowances
We understand the following facts: 1. […] (“Distributor”) and Marketer are GST/HST registrants; 2. ... You have submitted sample contracts outlining the terms and conditions under which the Allowances are paid to Retailers by Marketer; Sample Contract No. 1 – […] 9. ... The Retailer, and not the Wholesaler, is the person who is entitled to be paid the Allowance pursuant to the agreement, and the Wholesaler receives the Allowance from Distributor on behalf of the Retailer; Sample Contract No. 2 – […] 15. ...
GST/HST Interpretation
6 March 1996 GST/HST Interpretation 11915-7-2[1] - The Application of GST to Supplies of Swimming Lessons by Private, For-profit Organizations
Subsection XXXXX of XXXXX indicates that the following documents should be considered as lifeguard certificates: • XXXXX • a certificate that XXXXX considers equivalent to the certificates mentioned in clauses (a), (b) or (c). 5. Subsection 17(10) of the Regulation indicates that the following should be considered as assistant lifeguard certificates: • XXXXX • any of the certificates mentioned in subsection 17(9); or • a certificate that the XXXXX considers equivalent to a qualification referred to in clauses (a), (b) or (c). ... Venne Director Special Sectors GST Rulings & Interpretations c.c.: J. ...
GST/HST Interpretation
15 August 2016 GST/HST Interpretation 172758 - Camps for individuals who have a disability
The Charity currently has [#] [camps]: […][list of location of camps] 6. ... [Camp] seasonal program staff members participate in a pre-season training program. […] 14. […] 15. ... The factors the CRA takes into consideration in determining whether a recreational or athletic activity or program is intended to be provided primarily to individuals who have a disability include: * The purpose of the organization/program as set out in its governing documents; * How the organization/program is promoted or advertised; * The nature of the activities provided; * The qualifications of instructors/staff; * The ratio of staff to participants; * Whether healthcare services are provided as part of the program; * The nature design and use of the facilities; and * How participants in the program are selected. ...
GST/HST Interpretation
1 September 2020 GST/HST Interpretation 193533 - Supply of jet fuel to non-resident airline
FuelCo purchases jet fuel from […] and […][X] and [stores the jet fuel in a shared fuel storage facility “the fuel farm”] […]. ... Some of the NonResAir airlines are registered for the GST/HST, while others are not. 5. […]. […] (“Operator”), currently operates and manages the Airport fuel farm. 6. The fuel farm is used by […] and […][X], 2nd tier intermediaries such as FuelCo, and individual airline companies. 7. ...