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GST/HST Ruling

24 June 2016 GST/HST Ruling 164961 - Application of GST/HST to services regarding travel insurance

. / 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. ... It earns commissions from the sale of travel products including flights, travel packages, hotels, cruises, resort stays, bus tours, as well as commissions from the sale of travel insurance issued by […](the Insurer), a licensed insurer. […] The Agency entered into an agreement (the Agreement) with the Insurer, […]. […][Responsibilities of the Agency] […] The Insurer is responsible for claims administration, and for providing the Agency’s staff with training related to the insurance products. ... The Agency is paid a percentage of the premiums as a commission by the Insurer for its insurance sales, based on the type of insurance product sold […]. ...
GST/HST Ruling

6 December 2001 GST/HST Ruling 35825 - Services Provided by Condominium Corporation

The Basic Services Package will include: •   on-site management and service personnel, whose duties include monitoring and responding to security, health and emergency calls as well as reception and concierge services; •   use of the XXXXX facilities, including the social centre; •   nutritional and medication counselling, education and consultation on health matters, co-ordination and scheduling of in-suite personal assistance and care services; •   provision of cultural, educational, recreational and social programs; •   transportation to shopping; •   in-suite (one hour/month) housekeeping, plus emergency repairs; and a credit towards daily lunch and dinner services. 14. ... The Condominium Services Agreement makes reference to a particular arrangement terminating "... upon the earlier of XXXXX ceasing to be the lessee of the XXXXX.... ... The Additional Services include the following: •   direct nursing care and medication assistance provided by a Registered Nurse or a Registered Practical Nurse; •   foot care provided by a Registered Nurse; •   assisted living (HSW/PSW- terms not defined); •   hydro therapy assistance; and •   housekeeping and handyman services, catered events, shuttle transportation arrangements. ...
GST/HST Ruling

13 July 2021 GST/HST Ruling 212992 - Question on eligibility for 83% Public Service Bodies Rebate

. / 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 We understand, from your letter dated [mm/dd/yyyy]], with supporting documentation; from correspondence you sent, and […]; from phone conversations […]; and from the Corporation’s website […], that: 1. ... It was, therefore, not entitled to claim an 83% […] PSB rebate. However, as indicated above, as a charity, the Corporation was entitled to claim a 50% […] PSB rebate of the non-creditable tax charged paid or payable on eligible purchases and expenses related to the construction of the hospice. ...
GST/HST Ruling

8 February 2018 GST/HST Ruling 181264 - GST/HST rebate on regional administrative costs

STATEMENT OF FACTS We understand the following: 1. […][Information about the Corporation's structure]. 2. […]. 3. ... In order to claim an 83% rebate for […] operations […] [the LTC homes] would have to be qualifying facilities and the Corporation would have to be making facility supplies in these homes. ... The Corporation receives the majority of its funding from [Province A]. […]. ...
GST/HST Ruling

4 August 2010 GST/HST Ruling 110323 - Eligibility to Claim the 83% Public Service Body Rebate With Respect to the Operation of a XXXXX Centre

. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence. ... XXXXX also provides health promotion and illness prevention services to individuals, groups and the community, XXXXX: Community outreach XXXXX XXXXX XXXXX 6. ... According to XXXXX to the Agreement, the following is a detailed description of the services to be provided by XXXXX: XXXXX:- XXXXX: 16. ...
GST/HST Ruling

3 July 2001 GST/HST Ruling 36087 - Application of GST/HST Under Subsection 9(2) of Part I of Schedule V to the Excise Tax Act (the "Act")

Statement of Facts Our understanding of the facts, the transaction, and the purpose of the transaction is as follows: •   In the 1950's your client, XXXXX, became the legal owner of Lot 3 XXXXX ("Lot 3") which is approximately XXXXX acres of farmland. •   In XXXXX, Plan XXXXX was registered which subdivided part of Lot 3. •   The XXXXX access to the XXXXX River was subdivided into XXXXX lots and a road was constructed to give access to the landlocked farmland to the south. •   During the 1980's, XXXXX acres on the XXXXX corner of Lot 3 was sold to a corporation owned by your client. •   Since the advent of the GST on January 1, 1991, your client is the legal owner of one waterfront ("Lot 33") and approximately XXXXX acres of farmland at the XXXXX end of Lot 3. •   Your client has not severed or subdivided Lot 3 since January 1, 1991. •   Lot 33 has been used by your client's family for recreation use. ... The land is currently vacant. •   Your client is contemplating the sale of Lot 33 to a person other than a related individual, a former spouse or common-law partner of your client. ... Sherbaniuk, " Retrospectivity in Canadian Tax Legislation ", in Report of Proceedings of the Thirty-fifth Tax Conference, 1983 Conference Report 727 at pp 728-30. ...
GST/HST Ruling

7 August 1998 GST/HST Ruling HQR0001080 - Application of the GST/HST to Supplies of Literature Made by a Registered Charity

Statement of Facts •   The Society is registered for GST purposes with business number XXXXX[.] •   For GST purposes, the Society x qualifies as a charity. •   The Society x is dedicated to providing information and skills that promote safety in, on and around water. The Society's Mission is XXXXX[.] •   The Society's activities include: XXXXX XXXXX XXXXX XXXXX[.] •   The XXXXX consists of a national body (National XXXXX individual provincial branches (Branches). •   The National and each of the Branches is a separately registered charity and each is considered a separate "person" for GST purposes. •   The National's responsibilities include acting as the sole distributor of all the XXXXX national programs, products, services and activities to the Branches. •   Revenue is generated through the sale of awards, literature, equipment and merchandise, grants, and donations and miscellaneous fund raising. •   XXXXX of the National's revenues are derived from the sale of awards and literature to the Branches. •   Currently the sale of literature by the Society is treated as the sale of new goods so that the GST is charged. ... •   Is the sale of inventory by the National to the Branches taxable for GST purposes under the new model? ...
GST/HST Ruling

4 November 1998 GST/HST Ruling HQR0001325 - Application of the GST/HST to the Sale of Lots

4 November 1998 GST/HST Ruling HQR0001325- Application of the GST/HST to the Sale of Lots Unedited CRA Tags ETA 123(1) builder; ETA 123(1) residential complex; ETA 191(1); ETA Sch V, Part I, 2; ETA Sch V, Part I, 4; ETA Sch V, Part I, 14 GST/HST Rulings and Interpretations  Directorate Place Vanier, Tower C, 10th Floor 25 McArthur Avenue Vanier, ON K1A 0L5 XXXXX XXXXX XXXXX XXXXX Case: HQR0001325 File: 11870-3; 11870-5                                                                         Business Number: XXXXX Attention: XXXXX November 4, 1998 Subject: GST/HST APPLICATION RULING XXXXX Dear XXXXX Thank you for your letter of August 5, 1998 (with attachments), concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transactions described below, which was forwarded to our office by the Southern Ontario TIS Centre for reply. ... In describing the development proposal, XXXXX Amendment stated as follows: "Key planning considerations incidental to the proposed lot design include: •     maintain uniformity in the configuration of all proposed lots; •     providing equitable shoreline frontage and area for each of the proposed lots; •     maintaining the historic integrity of this waterfront estate development; •     ensuring acceptable setbacks to existing dwellings, accessory buildings/structures, well and septic services; •     ensuring that functional waterfront area and lake access are provided for each lot/dwelling... ... Yours truly, Michael Wolff Real Property Unit Financial Institutions & Real Property Division GST/HST Rulings and Interpretations Directorate c.c.: XXXXX Encl.: GST/HST Memoranda Series, section 1.4 Legislative References:           Excise Tax Act, subsection 123(1) builder residential complex Excise Tax Act, subsection 191(1) Excise Tax Act, Schedule V, Part I, section 2 Excise Tax Act, Schedule V, Part I, section 4 Excise Tax Act, Schedule V, Part I, section 14 NCS Subject Code(s): 11870-3, 11870-5 ...
GST/HST Ruling

23 March 2021 GST/HST Ruling 196248r - […][Assignment of a right to purchase a residential condominium unit]

. / 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. ... On [mm/dd/yyyy], you entered into an agreement of purchase and sale (the Agreement) with […](the Vendor) with respect to a [#] bedroom and [#] bathroom residential condominium unit (the Unit) that would have a municipal address [in Canada] […]. The Agreement indicates that you agreed to purchase the Unit for $[…] including [GST/HST]. ...
GST/HST Ruling

1 September 1996 GST/HST Ruling 11870-2[1] - Sale of Bed and Breakfast

1 September 1996 GST/HST Ruling 11870-2[1]- Sale of Bed and Breakfast Unedited CRA Tags ETA 190; ETA 254; ETA 123(1) residential complex; ETA 136(2); ETA 167(1) XXXXX File: 11870-2, 11950-3, XXXXX                 11783-2/123(1) XXXXX                 s. 190, 254, ss. 123(1), 136(2), XXXXX                 167(1), V/I/2, V/I/9 XXXXX                 Subject: GST APPLICATION RULING Sale of Bed & Breakfast XXXXX XXXXX XXXXX Dear XXXXX Generally, as XXXXX stated in his explanation to XXXXX sales of used residential complexes are exempt from GST under section 2 of Part I of Schedule V to the Excise Tax Act ("Act"). ... As well, while the purchaser, if a registrant, may be required to remit the GST by using the form GST 60 (The Goods and Services Tax Return for the acquisition of Real Property), if the purchaser decides to continue the bed & breakfast business, XXXXX and the purchaser may be entitled to file the election under subsections 167(1) and (1.1) of the Act. ... John Sitka A/Director Financial Institutions & Real Property Division GST Rulings & Interpretations Directorate ...

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