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GST/HST Ruling

20 April 2021 GST/HST Ruling 197397 - AND INTERPRETATION - GST/HST on supplies related to a game

The Corporation is planning a marketing project where it would give away [#] […][prizes] […]. ... The winner has the option of choosing […][the prize] or a cash payment [the cash]. […] […][The cash] option is expected to be about $[…]. ... Yours truly, Desneiges Arbour Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate         ...
GST/HST Ruling

22 May 2014 GST/HST Ruling 156633 - Application of the GST/HST to a lease of real property on which an apartment building is constructed

STATEMENT OF FACTS We understand the following from your letter and your phone message of [mm/dd/yyyy]: 1. […] (the Lessee) entered into a lease agreement (the Agreement) with […] (the Lessor) whereby the Lessee will lease certain real property (the Property) located at […]. ... Under the Agreement, the Ground Rent payment will be $[…] for the first […] years of the Term of the Agreement and will increase every […] years as indicated therein. […]. 4. ... We make specific note of the following content of the Agreement: a) Paragraph […] states that the Construction Period will begin on [mm/dd/yyyy] and end on the earlier of [mm/dd/yyyy] and the date an occupancy permit is issued by […] in respect of the Complex. b) Paragraph […] indicates that the Term of the lease is […] years which, pursuant to paragraph […], will commence on the first day after the expiry of the Construction Period (the Commencement Date). ...
GST/HST Ruling

17 December 2013 GST/HST Ruling 153989 - A "public college" pursuant to subsection 123(1) of the Excise Tax Act

. / 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. ... [Province X]. 2) The Regulations to the Letters Patent of [the Organization] include: i) [...] states that [the Organization] is a not-for-profit organization that is responsible for funding education and training that it offers; ii) [...] states that [the Organization] is recognized by the Government of [Province X] as an integral part of the post-secondary system of education in [Province X] as it offers quality training in French. iii) [...] lists [the Organization]'s objectives [...] to accomplish its mission, [the Organization] has the responsibility to: a) be self-financing. b) promote continuing education programs and general interest courses [...], training and development for the adult population of [Province X]. c) make available to adults of [Province X] continuing education programs and general interest courses, training and development. d) [...]. e) organize, administer and provide training programs focused on employment, community training and personal training, as well as continuing education programs and general interest courses. f) issue certificates specifying that the students have followed the required courses and completed all related requirements. g) work with other stakeholders in the field of education and adult learning in [Province X] and [...] for the delivery of adult education in the province. h) [...]. i) [...]. 3) [The Organization]: i) offers the following post-secondary programs leading to a certificate/diploma: bilingual administrative assistant, bilingual bookkeeper, early childhood education, human services intervention worker, resident care worker, practical nursing program, and welding, all of which require the student to have a high school diploma or equivalency as an entrance requirement; ii) offers French language training courses at various levels ([...]); iii) provides training to adults working towards obtaining their grade 12 equivalency or their grade 12 academic certificate through its various centres; iv) provides training to individuals who need to work towards writing their GED exam; and v) offers general interest courses, such as, First Aid, WHMIS, and introduction to computers. 4) [...]. 5) [...]. 6) [...] indicates that the Government (of [Province X]) recognizes [the Organization]'s services as an integral part of the post-secondary education system. 7) [...] states that the: Government (of [Province X]) wishes to recognize [the Organization] as a publicly funded educational institution. 8) [...] provides for the potential for a subsequent [...] at the expiration of the current one. ... The conditions that have been met by [the Organization] that qualifies it as a "public college" are: * it is operating a post-secondary college or post-secondary technical institute; * it receives funds from a government that are for the purpose of assisting [the Organization] with its ongoing provision of educational services to the general public; and * the primary purpose of [the Organization] is to provide programs of instruction in one or more fields of vocational, technical or general education. ...
GST/HST Ruling

3 August 2021 GST/HST Ruling 211272 - Assignment of a right to purchase a residential condominium unit

According to the APS: a) the Assignor was required to pay, to the Vendor, a purchase price in the amount of $[…] for the Unit; […][GST/HST] was not included in the price. b) the Assignor was required to pay, to the Vendor, a total deposit amount of $[…] in four installments: (i) Initial: $[…] (that is, [#]% of the purchase price) due at the time the APS is accepted by the Vendor; (ii) Second: $[…] (that is, [#]% of the purchase price) due on the later of [mm/dd/yyyy] and the [#] business day after the delivery of a document entitled Amendment to the Purchaser; (iii) Third: $[…] (that is, [#]% of the purchase price) due on [mm/dd/yyyy]; and (iv) Fourth: $[…] (that is, [#]% of the purchase price) due on [mm/dd/yyyy]. c) the Assignor was required to pay, to the Vendor, the balance of the purchase price (presumably, $[…], subject to closing adjustments including [GST/HST]) on the closing date. 6. The total deposit amount (that is, $[…]) was paid by the Assignor. 7. ... According to the Assignment Agreement, the Assignor’s Statement of adjustments and the Assignor’s signed direction to […](the Assignor’s legal representative) entitled “Order to pay”: a) the Assignee was required to pay, to the Assignor, an assignment amount of $[…] for the assignment of his rights in the APS. $[…] was payable as a deposit and the remaining balance of $[…] was payable to the assignee’s solicitor within [#] business days of receiving the fully executed assignment contract signed by the Vendor, and to the assignor’s solicitor within [#] business days of receiving the fully executed assignment contract signed by the Vendor; b) the assignment amount included an amount to reimburse the Assignor for the Deposit of $[…] that was paid according to the APS, thus the Assignor’s profit before assignment fees and commissions was $[…]; c) the Assignor was required to pay, to the Vendor, an assignment and filing fee totalling $[…]; d) the Assignor was responsible for paying real estate commission to both the listing and selling agents in respect of the assignment of the Assignor’s rights in the APS, which was a total of $[…]; e) the Assignor’s accountancy fees, $[…], and legal fees and related disbursements, estimated to be $[…], totalled $[…]; f) the Assignor’s loss after fees and commissions was $[…]; and g) the assignment amount (that is, $[…]) was inclusive of any [GST/HST] payable with respect to the assignment of the Assignor’s rights in the APS, and the Assignor must remit any [GST/HST] payable. 13. ...
GST/HST Ruling

24 October 2012 GST/HST Ruling 94993 - The application of GST/HST to real estate valuations

. / 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 * Your company occasionally supplies real estate valuations for insurance claims. * You supplied two fire insurance reports to us as samples of your work: 1) […][Address in Canada], produced for […] and 2) […][Address in Canada], for […]. * The report for the first case stated at page [#]: “Property inspection –... ... In this particular situation valuation services that concern property insurance claims the service would be exempt under the definition of financial service in subsection 123(1) if it complied with paragraph (j.1) of that definition and was not excluded by paragraph (r). ...
GST/HST Ruling

31 August 2012 GST/HST Ruling 143522r - Supply of Bottled Juice

Both products are sold in [#] ml bottles that are sealed […]. 3. […] [weight of raw fruit used in production]. 4. Bottle labelling suggests individuals […] [suggested serving size] 5. ... RULING REQUESTED You would like to know if the supply of your […] juice blends, in [#] ml bottles, is subject to GST/HST. ...
GST/HST Ruling

13 July 2020 GST/HST Ruling 198971 - Input tax credit entitlements related to […][the Program]

The purpose of the Corporation is […] 3. The members of the Corporation are: […][Member #1], […]. 4. ... [Member #1] registered for GST/HST purposes on [mm/dd/yyyy]. 14. […]. 15. ... Yours truly, Desneiges Arbour Charities and Non-profit Organizations Unit Public Service Bodies and Governments Division Excise and GST/HST Rulings Directorate FOOTNOTES 1 […]. 2 […]. 3 […].     ...
GST/HST Ruling

18 January 2013 GST/HST Ruling 148702 - Sale of interest in family cottage

At the time of purchase, the Property was a vacant lake-front parcel of land, […] feet wide and […] feet deep. ... You took out building permits and built a […] square foot cottage on the Property in [yyyy]. ... Yours truly, Eric Paraskake Real Property Unit Financial Institutions and Real Property Division Excise and GST/HST Rulings Directorate     ...
GST/HST Ruling

20 July 2020 GST/HST Ruling 210845 - […][Event] Sponsorships

STATEMENT OF FACTS We understand the facts as follows, based on the information provided, our telephone conversations, and the website […]: 1. […] ([…][the Organization]) is part of […]. ... To ensure [the Event was] successful […], […] [the Organization] enlisted the participation of sponsors. ... The agreement with [Sponsor #1] included the following clauses: […][Clauses from the agreement including sponsorship rights and consideration payable] […] [Sponsor #1 sponsored a video] 12. […] stated that the […] video was shared […][online]. […] Agreement with [Sponsor #2] 13. ...
GST/HST Ruling

20 June 2024 GST/HST Ruling 247341 - Delivery services provided through […][the Platform]

The Platform may provide refunds for delivery services]. […]: […][The Platform limits its liability for the delivery service to the consumer to the amount paid by the consumer for that service] […] 3. ... The delivery driver provides its services to the Platform, which the Platform provides to consumers or merchants] […][Information on relationship between a delivery driver and the Platform] […] […]: […][Definitions] 4. […][Information on the Platform webpage about refunds to consumers. ... Sincerely, David Phoenix, CPA, CGA Industry Sector Specialist Services and Intangibles Unit General Operations and Border Issues Division GST/HST Rulings Directorate FOOTNOTES 1. […] 2. […] 3. […] ...

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