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GST/HST Ruling

22 September 2011 GST/HST Ruling 129475 - GST/HST RULING - Application of HST to international student program

Section [...] of the [ABC] Agreement states [...]. 40. Section [...] of the [ABC] Agreement states [...]. 41. ... Section [...] states [...]. 43. Pursuant to section [...], if [Company B] [...]. 44. ... Section [...] states [...]. 50. Sub-paragraph [...] states [...] 51. The MOU sets out the roles and responsibilities of the Corporation as follows: [...] 52. ...
GST/HST Ruling

26 July 2013 GST/HST Ruling 96569 - GST/HST Treatment of the sale of condominiums for subsequent use in a rental pool arrangement

The Development is situated in [...] [Location A], [...]. 2. The Development is being constructed [...] and, when completed, will include [...] ... The key provisions of the Agreement are as follows: [...]- Each owner of a Unit in the rental pool is entitled to share in [...] ... [documents about the overall financial performance of the rental pool and details about the individual owner's final share] [...]- The Manager collects GST/HST and other taxes from guests on behalf of the owners. [...]- The Manager is entitled to a [...] management fee equal to [...]. ...
GST/HST Ruling

29 March 2012 GST/HST Ruling 129519 - GST/HST Ruling - Point-of-Sale book rebate on the supply of instructor manuals

It contains [#] progressive modules and [#] appendices totalling [#] pages. ... (Product D) [...]- This publication is understood to contain [#] chapters and one appendix, and is used to assist [...] b. [...] (Product E) [...]- This publication is understood to contain [#] sections used to train instructors [...] c. [...] ...
GST/HST Ruling

10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction

We reviewed the following documents in connection with your request: * […][Agreement 1] dated [mm/dd/yyyy] […] between [the Investor] and […](Corporation 1); and * […][Agreement 2] dated [mm/dd/yyyy] […] between [the Investor] and a non-resident corporation (Corporation 2). ... [Agreement 1] includes the following key provisions: Recital “The Purchaser [[…][the Investor]] wishes to acquire from the Corporation, […], a gross sales royalty […] on the terms and conditions contained herein.” […] Gross Sales Royalty “As consideration for the payment by the Purchaser of the Royalty Acquisition Amount, and subject to the terms hereof, the Corporation […] agrees to pay to the Purchaser a royalty payment ([…] a “Royalty Payment”) equal to […]% of monthly IP Revenue earned by the Corporation during each calendar month, […].” […] Buyout Option “[…] the Corporation shall have the right to purchase and extinguish, fully and not in part, all amounts owing to the Purchaser […], in accordance with the following (the “Buyout Option”): …” […] No Interest The Purchaser is not granted interest in any assets or Business IP of the Corporation. ... [Agreement 2] includes the following key provisions: Recitals “[…] the Purchaser wishes to acquire from the Corporation, […] a gross sales royalty […].” […] Gross Sales Royalty “As consideration for, […], the payment by the Purchaser of the Initial Installment and, if applicable, the Second Installment, […], the Corporation […] agrees to pay to the Purchaser a royalty amount ([…] a “Royalty Payment”) equal to […]% of monthly IP Revenue […] (the “Gross Sales Royalty”). […].” […] Minimum Royalties “[…] [No] Royalty Payment in respect of a calendar month will be less than $[…], […] referred to as the “Minimum Monthly Amounts”. […].” […] Buyout Option […], the Corporation may […] purchase and extinguish […]% […] of all amounts owing or to become owing to the Purchaser […] […] Acknowledgements of the Purchaser “The Purchaser acknowledges and agrees that: (b) this Agreement and the royalties paid or payable […] do not confer on the Purchaser any right, title, or interest in any assets […] other than the rights to receive the payments set out herein.” […] RULINGS REQUESTED In relation to [Agreement 1], you would like to know: 1. ...
GST/HST Ruling

27 March 2012 GST/HST Ruling 129347 - GST/HST Ruling - Place of Supply of Services

("[...] [Plan A]"), [...] and [...] ("[...][Plan B]"), [...]. 3. ... The Contracting Authority is identified as [...] ("[...] [the Contracting Authority]"), [...]. ... ("[...] [the Project Authority]") and is located in [...] [City 2]. ...
GST/HST Ruling

12 June 2013 GST/HST Ruling 142072 - /INTERPRETATION - Application of the GST/HST to supplies made by [...][the Corporation]

Directors of [the Corporation] * [...] [...][member type A] * [...] [...][member type B]; * [...][member type C]; * [...][member type D]; and * [...] ... [organization] membership fees; [...] fees; [...][coach training] program fees; Educational program registration fees ([...]); Registration fees for [sport] events; Hosting sanctions fees; [Electronic] program fees; and Fees for tangible personal property (e.g. [...]). ...
GST/HST Ruling

29 July 2015 GST/HST Ruling 163652 - Application of GST/HST to the supply of […][a snack food product]

The sample contains the following information on the package: * Ingredients: […] * Contains: […] * Nutrition Facts: […] 4. ... Each piece measures approximately […] centimetres in diameter, and is about […] millimetres thick. […]. 9. ... It is […] similar to the type of texture commonly found in chips or crisps. * Cooking process: The Product is […], similar to other […] chips. * Size and shape: The Product is […] in shape. ...
GST/HST Ruling

8 March 2012 GST/HST Ruling 137942 - GST/HST Ruling - Payment made under a termination agreement

[Company X's] parent company [...] issued the [...] and the [...] ... [Country X] (the exception consisting of [...] valued at $[...]) on behalf of [Company Y]. ... [Direct quote] thus supporting the input tax credit (ITC) claimed on the payment to [Company Y] ([#] of $[...] = $[...]). [Company X] claimed the ITC of $[...] despite [Company Y] not issuing an invoice stipulating the amount of [...] ...
GST/HST Ruling

6 September 2011 GST/HST Ruling 77006 - GST/HST RULING - Application of GST/HST to services performed related to credit card accounts

(FinanceCo), and [...] (Service Provider), [...] have entered into a [...] ... The first group of services are the [...] [A] Services (section [...] of the Agreement). ... A few examples of such services are provided below: [...]: on-line application entry and processing of applications based on FinanceCo's selected criteria. [...]: post cardholder financial adjustments such as balance and cash and finance charges. [...]: creating cardholder file with account information such as account balance and posting all pending authorizations to cardholder accounts through on-line enquiry. [...]: processing and rendering of billing statements. [...]: embossing, issuing, reissuing and replacing cards. [...]: on-line statements, account cycle and miscellaneous history. 7. ...
GST/HST Ruling

14 July 2003 GST/HST Ruling 38529 - Membership Fees

The goals of the Association are: •   To represent XXXXX. •   To provide continuing education programs XXXXX. •   To remain non-profit and to ensure all funds collected by the Association are returned to the membership for the betterment of the members. •   To provide certification for qualified members. •   To promote the career of XXXXX to the profession, the community and to government XXXXX. ... The Association has two membership categories: Voting Members •   XXXXX •   XXXXX Non-voting Members •   XXXXX •   XXXXX •   XXXXX Membership in the Association provides members with many benefits, including the following: •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX •   XXXXX the total fee for membership in the Association is $XXXXX. ... Gaudet Charities, Non-Profit Organizations and Educational Services Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate XXXXX  Legislative References: 123(1) "non-profit organization"; sections 17 & 18 of Part VI of Schedule V. ...

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