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GST/HST Ruling

15 July 2005 GST/HST Ruling 59548 - Application of GST/HST to Cranberry Juice

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... We provide the following in response to your questions: 1 & 2. Depending on the facts of a particular situation, it may appear that there is an advantage when a significant portion of a tour package is short-term accommodation. ... Yours truly, Alyson Trattner Manager, Services and Intangibles Unit General Operations and Border Issues Division Excise and GST/HST Rulings Directorate APPENDIX A- Tour Package elements: Short-term accommodation $ 930.00 Tour package purchased * $ 1,200.00 GST on accommodation 65.10 GST on tour package 84.00 less: Rebate (100% of GST paid) 65.10 less: Rebate (50% of GST paid on package) 42.00 Non-registered, non-resident tour operator's cost to operator's cost to acquire element acquire element forms part of the larger Tour Package Tour package includes short-term accommodation at a hotel or resort $ 930.00 Non-registered, non-resident tour $ 1,242.00 Supply made by a non-registered, non-resident tour operator (NR/NR) to a non-resident Operator's selling price $ 2,598.00 20% mark-up on cost ($930 + $1,200) GST not applicable- plus GST not rebated ($42)  ------------- Operator's revenue $ 2,598.00 Operator's revenue $ 2,598.00 less: Short-term accommodation 930.00 less: Tour package 1,242.00 includes GST paid and not rebated ($42)  -------------- Net amount $ 426.00 (before other expenses) Registered tour operator's amount charged to customer Operator's revenue (consideration) $ 2,510.15 GST 175.71 less: Rebate 87.86  ------------- $ 2,598.00 amount the same as the NR/NR's selling price Supply made by a registered tour operator to a non-resident Operator's revenue (consideration) $ 2,510.15 less: Short-term accommodation 930.00 registered tour operator entitled to claim ITC for GST less: Tour package 1,200.00 registered tour operator entitled to claim ITC for GST  ------------ Net amount $ 380.15 (before other expenses) 2005/07/25 RITS 60361 Monitoring Services ...
GST/HST Ruling

7 April 2010 GST/HST Ruling 114205 - Application of GST/HST to XXXXX Juice

The Product label states: XXXXX. Recommended Use: XXXXX. WARNING: Consult a health care practitioner prior to use if you are pregnant or breastfeeding. XXXXX. Medicinal Ingredients: XXXXX. Non medicinal Ingredients: XXXXX. Serving Portion XXXXX. XXXXX. No artificial flavours, colours, or sweeteners, and no added sugar. Refrigerate after opening. 10. The XXXXX Website states: XXXXX XXXXX XXXXX Ruling Requested You would like to know how the GST/HST applies to supplies of the Product. ...
GST/HST Ruling

7 November 2002 GST/HST Ruling 41783 - GST/HST Ruling Request for Dietary Supplements

XXXXX (Product C) •   Product C is a XXXXX energy bar •   The flavours of Product C are: XXXXX •   All of the flavours of Product C are XXXXX chocolate-coated. 4. ... XXXXX (Product G) •   Product G is an XXXXX powder •   Product G states "Note: For therapeutic use only" •   Product G directions state, XXXXX •   Product G is labelled as a vitamin and mineral supplement 8. ... XXXXX (Product I) •   Product I is an XXXXX powder •   Product I states "Note: For therapeutic use only" •   Product I directions state XXXXX •   Product I is labelled as a vitamin and mineral supplement 10. ...
GST/HST Ruling

30 December 2013 GST/HST Ruling 136499 - Application of GST/HST to fees related to loans provided by a limited partnership

Section [...] provides that the capital commitment of each Limited Partner shall be equal to $[...] multiplied by the number of units ([...]), whereas the capital commitment of General Partner in respect of the interest of the General Partner is $[...]. 6. ... Based on section [...], the net income of the Partnership for each Fiscal Year shall be allocated to the [...] ... The General Partner receives amounts for a capital commitment of $[...] whereas, each Limited Partner's capital commitment is $[...] multiplied by the number of units, [...]. ...
GST/HST Ruling

7 February 2022 GST/HST Ruling 210585 - Application of the GST/HST to the supply made by a minor hockey association of registering a participant in a minor hockey program

It states, “[…]” 4. The Program consists of the following age groups. ... The Manual states the following on the subject of registration fees charged by the Association for participation in the Program, […] Items to be included in the cost of registration fees shall include: […] Player Insurance Ice Costs Jersey Fund Socks Pictures Administration 8. ... A supply will be exempt under section 12 of Part VI of Schedule V where: * The supplier is a public sector body (which is defined to include a non-profit organization); * The supply is of a membership in a program or services supplied as part of a program; * The program is established and operated by the public sector body; * The program consists of a series of supervised instructional classes or activities involving athletics, outdoor recreation, music, dance, arts, crafts or other hobbies or recreational pursuits; * One of the following circumstances applies: * The program is provided primarily to children 14 years of age or under and it does not involve overnight supervision throughout a substantial part of the program; or * The program is provided primarily to underprivileged individuals or individuals with a disability. ...
GST/HST Ruling

29 January 2015 GST/HST Ruling 93176 - GST/HST on fees relating to a loan

You provided a copy of the following documentation: * Term Sheet dated [mm/dd/yyyy], between […][ACo] and […][BCo]; * Assignment Agreement dated [mm/dd/yyyy], between [ACo], […][CCo], and [BCo].; and * Acknowledgement and Agreement dated [mm/dd/yyyy], 2013, addressed to [CCo] and signed by […] on behalf of [BCo]. ... The Term Sheet set out terms and conditions that would be subject to the full scrutiny of a due diligence review that would include, but not necessarily be restricted to, considerations contemplated therein, as follows: * Borrower: [BCo] * Lender: [ACo] or any company [ACo] chooses to use * Loan Facility: a demand term loan in the amount of $[…] * Rate of Interest: […] plus […]% per annum payable monthly in arrears. * Commitment Fee: $[…] plus HST is payable on the execution by [BCo] of the Lender’s Commitment Letter (which we understand to be the Term Sheet itself). * Closing Fee: [BCo] agrees to pay a fee equal to [#]% of the maximum of the Loan Facility, which is earned at the time the Lender first advances the Loan Facility with payments being postponed until the earlier of the maturity date of the Loan Facility or payout of the Loan Facility. * Term: […] months, on demand. * Interest Rate Adjustment Date: [BCo] shall pay interest on the entire loan facility amounts monthly, in arrears, on the 30th day of each month. ... On [mm/dd/yyyy], [ACo], [CCo], and [BCo] entered into an Assignment Agreement (Assignment Agreement) which contained the following provisions: * Pursuant to the Term Sheet, [ACo] agrees to make certain loans and advances to [BCo], subject to the terms and conditions of the Term Sheet (the “Credit Facilities”); * Pursuant to terms of the Term Sheet, [ACo] has the discretion as to the entity that will enter into the loan arrangements with [BCo] and fund the advances made to [BCo] pursuant to the Term Sheet; * [ACo] has designated [CCo] as the Lender under the Term Sheet; * For consideration of $[…] paid by [CCo] to [ACo], [ACo] assigns to [CCo] all of its right, title and interest in the Term Sheet and the Credit Facilities. * [ACo] represents that the Term Sheet is in full force and effect and unamended and [ACo] has not knowingly discharged [BCo] from the Term Sheet or assigned any rights or obligations under the Term Sheet; * [CCo] accepts the assignment of [ACo]’s rights and obligations in the Term Sheet and indemnifies [ACo] from any claims by [BCo] arising in connection with the Term Sheet or the performance of the Lender’s obligations under the Term Sheet; * [BCo] acknowledges that it has taken notice of the assignment and expressly consents to it. * The Assignment Agreement sets forth the entire agreement and understanding among the parties with respect to the subject matter and supersedes any prior agreements or understandings, whether oral or in writing. ...
GST/HST Ruling

29 August 2011 GST/HST Ruling 81229 - GST/HST RULING - GST/HST treatment of trailer park site rental

The Park is located at [...] in [...] [Community 1], in the municipality of [...], [...] ... You own your unit, a [...] park model, which measures [...]' x [...]'. ... The site is fully landscaped and has a [...]' x [...]' concrete driveway. ...
GST/HST Ruling

14 February 2024 GST/HST Ruling 246201 - /INTERPRETATION - Supplies made through a distribution platform

Section [#] […]. f. Section [#] […][Information about the relationship between the parties]. ... As a consideration for the supply, [the Company] will generally pay the Creator in the form of a fixed amount (USD $[…]) calculated on the [X] awarded to the Creator […] and a share of net subscription revenues […]. ... This information is available in the GST/HST registry database maintained by the CRA at canada.ca/en/revenue-agency/services/tax/businesses/topics/gst-hst-businesses/digital-economy-gsthst/confirming-simplified-gst-hst-account-number 3. […] 4. […] 5. […] 6. […] 7. […] 8. […] 9. […] 10. […] 11. […] 12. […] 13. […] 14. […] 15. […] ...
GST/HST Ruling

25 May 2021 GST/HST Ruling 204710 - Amounts paid to a municipality pursuant to a licence agreement

These programs include the maintenance and servicing [by ACo] of […][X], including installation, repair and replacement, and […]. 4. […]. ... The term of [the Agreement] is […] commencing [mm/dd/yyyy] and ending on [mm/dd/yyyy], […]. 7. ... According to […] [the Agreement], [ACo] will pay […] to [the Municipality] […] for the duration of the agreement. […] 9. […][Other matters clarified in the Agreement]. 10. ...
GST/HST Ruling

10 October 2012 GST/HST Ruling 147921 - Value of temporary importation of leased bus

. / 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. ... We understand that: * […] (the “Lessee”) has entered into an agreement to lease the following bus from […] (the “Lessor”), a non-resident person with whom the Lessee deals at arm’s length: Bus Type Model Number Serial Number Registration Number […] Not applicable […] Not applicable * The lease agreement is for a period beginning on [mm/dd/yyyy] and ending on [mm/dd/yyyy]. * The bus will be imported at […] on [mm/dd/yyyy] and will be exported on [mm/dd/yyyy]. * The total number of months that the bus is to be held in Canada by the Lessee under a lease with the Lessor will not exceed 24 months. ... A copy of this letter has been sent to the Canada Border Services Agency, Canada Border Services Office […]. ...

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