Search - 2002年 抽纸品牌 质量排名

8 February 2002 GST/HST Interpretation 37008- Asset Securitization- Unedited CRA Tags ETA 123(1) financial service; ETA 138; ETA 139 John Nowak Financial Institutions & Real Property Excise & GST/HST Rulings Unit February 8, 2002XXXXX3700811590-5/11595-2/11600-7 Subject: Asset Securitization- XXXXX The letter from XXXXX proposes the interpretation that administrative services carried out as a part of a mortgage securitization program form part of a single supply of the sale of the mortgages, and by operation of section 138 or 139 as applicable, are deemed to be a financial service and therefore exempt of the GST/HST. ... Their argument also does not refer to " The Financial Services (GST/HST) Regulations ". ... Paragraph (t) of the definition of "financial services" and section 4 of the " Financial Services (GST/HST) Regulations " must also be reviewed in determining the tax status of the servicing fees. ...

The following information was presented in your letter. •   X Co. is a non-resident and is registered for purposes of the GST/HST. •   X Co. is engaged in the provision of consulting and data processing services and the supply of computer software. In addition, X Co. is an application service provider. •   As an application services provider, X Co. allows Canadian businesses to access software situated on its mainframe computer in the U.S. for all of their daily business needs without having to purchase a sophisticated computer hardware system. •   The software is used by the client for inventory control, accounting, sales documentation and other business purposes. •   The client uses X Co.'s software and facilities in order to carry out its data processing function. •   X Co. and the client enter into a separate agreement with respect to the use of the software. •   In the course of setting up the connection to its mainframe, X Co. will install networking equipment at the client's premises in Canada so that the client is able to access the mainframe in the U.S. •   X Co. issues a separate invoice for the installation of the networking equipment at the client's site. ... This latter charge is called an upfront fee. •   The access fee is also invoiced separately and is a monthly fee paid by the client for access to the mainframe. ...

27 September 2002 GST/HST Interpretation 35585- Case #35585- Unedited CRA Tags ETA Sch VI, Part III, 1 XXXXXKevin W. ... Labelling •   Labelled as a supplement •   Claims that the product has a therapeutic or preventative effect, enhances mental or physical performance, enhances physique, or promotes weight loss. •   Emphasizes a particular nutrient or ingredient found in the product either through the products name or otherwise identified on the label. •   Restrictions on consumption or warnings to who should not consume the product. Packaging & Format •   Packaged in pill, tablet or capsules. •   Packed in formats not usually associated with foodstuffs (e.g. eye droppers). •   The same product is presented in several different formats (i.e., pill, powder, or liquid). ...

23 January 2002 GST/HST Ruling 36706- GST Treatment of Leases that Go into Default Unedited CRA Tags ETA 136(1); ETA 152(2); ETA 153(4.1); ETA 153(4.6); ETA 153(5); ETA 168(2); ETA 182; ETA 225(1); ETA 231(1); ETA 231(3); GST/HST Memoranda Series Memorandum 1.4, Goods and Services Tax Rulings Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXAttention: XXXXX XXXXX Case Number: 36706Business Number: XXXXXJanuary 23, 2002 Subject: GST/HST APPLICATION RULING GST Treatment of Leases that go into Default Dear XXXXX: Thank you for your letter of July 3, 2001 (with attachments), concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the transaction(s) described below. ... GST & PST and a new demand that includes interest less salvage value is sent; the amount is written off (for accounting purposes) over the six months following the repossession. ... The main contract provisions relevant to my analysis of the GST treatment of the above-noted scenarios read as follows: XXXXX Transaction(s) My understanding of the flow of events and GST events, pursuant to the above-noted information, our conversations and the contracts is as follows: •   your client enters into the lease agreement (which may, in some situations, constitute a sale-leaseback transaction subject to subsection 153(4.1) of the ETA, that is to say, a transaction whereby the vendor/Lessee is not required to collect tax in respect of the supply of Equipment by way of sale to the Lessor and the Lessor immediately makes a taxable supply by way of lease of the property to the Lessee under an agreement) •   any prepaid lease payments are paid to your client who remits the GST accordingly •   your client provides the leased equipment to the Lessee •   your client issues monthly invoices to the Lessee and remits the GST accordingly (whether or not it receives the lease payment) •   the Lessee fails to make payment for three months and your client sends a notice to the Lessee •   the Event of Default occurs when the Lessee fails to make payment owing and such default continues for 15 days after notice •   pursuant to the Event of Default, your client repossesses the leased property •   the day following repossession, your client invoices the Lessee for the "remedy of repudiation" •   collection action is undertaken with respect to the missed payments as well as the "remedy of repudiation" •   at some point, either before or after the collection action is undertaken, the repossessed property is sold and your client remits GST on the sale (if applicable, general rules) •   collection action continues with respect to: the outstanding lease payments, the remedy of repudiation and any other amounts owing •   at a point six months, one year or 2 years following the Event of Default, the collection action either yields a portion of the money which remains owing to your client or yields no result and is discontinued. ...

16 January 2002 GST/HST Interpretation 37138- Tax Status of Brokerage Services Unedited CRA Tags ETA 142(1)(g); ETA 142(2); ETA 143(1); ETA 232; ETA Sch VI, Part V, 5 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXX Case Number: 37138Business Number: XXXXXJanuary 16, 2002 Subject: GST/HST Interpretation Tax Status of Brokerage Services Dear XXXXX: Thank you for your facsimile of August 27, 2001 (with attachments) addressed to Mr. ... Co) sells goods to purchasers, resident in Canada on a duty paid and delivered basis. •   U.S. ... Scenario 2 •   A non-resident imports goods into Canada for supply to Canadian purchasers. ...

17 December 2002 GST/HST Ruling 43024- Tax Status of Meal Replacement Bars and Drinks Unedited CRA Tags GST/HST Memoranda Series, Memorandum 1.4, Goods and Services Tax Rulings Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th Floor 320 Queen Street Ottawa, ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 43024December 17, 2002 Subject: GST/HST APPLICATION RULING Tax Status of XXXXX Bars and Drinks Dear XXXXX: This letter is further to our letter dated XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to XXXXX Bars and Drinks. ... Statement of Facts Our understanding of the facts is as follows: XXXXX Drinks (the Product) •   The Product is formulated with a XXXXX •   The Product is advertised as either a meal or a snack. •   The Product is available in XXXXX flavours. •   Ingredients in the XXXXX flavour of the Product include water, fructose, milk protein and cocoa. Ingredients in the XXXXX flavour of the Product include water, fructose and milk protein. •   The Product is packaged in XXXXX[.] ...

23 September 2002 GST/HST Interpretation 42342- Internet Access Unedited CRA Tags ETA 123(1) telecommunication service; ETA 123(1) telecommunications facility; ETA 142.1(2)(a) Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 42342XXXXX XXXXX September 23, 2002 Subject: GST/HST INTERPRETATION Internet Access Dear XXXXX: Thank you for your facsimile concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to a supply of Internet access. From your facsimile and our telephone conversations, our understanding of the situation is as follows: •   An Internet Service Provider (ISP) located in Canada supplies Internet access to a Canadian company's subsidiary located in the U.S; •   The Canadian company's subsidiary in the U.S. is not registered for GST/HST purposes; •   The ISP bills the Canadian company in U.S. dollars for the supply of the Internet access provided by the ISP to the subsidiary; and •   The server that enables connection to the Internet is located in the U.S. ... Interpretation Given Subsection 123(1) of the Excise Tax Act (the "Act") defines a "telecommunications facility" to be "... any facility, apparatus or other thing (including any wire, cable, radio, optical or other electromagnetic system, or any similar technical system, or any part thereof) that is used or is capable of being used for telecommunications". ...

5 July 2002 GST/HST Ruling 41140- Application of the GST/HST to Coconut Milk Unedited CRA Tags ETA Sch VI, Part III, 1 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXXAttention: XXXXX Case Number: 41140July 5, 2002 Subject: GST/HST APPLICATION RULING XXXXX Coconut Milk Thank you for your letter of XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to coconut milk. ... The Product is sold in a variety of different sized containers, including the XXXXX sample of the Product provided to us which is described below: •   The Product is packaged in a XXXXX sealed metal can. •   The ingredients of the Product are coconut extract, water, and citric acid (an antioxidant). •   The Product label states; XXXXX •   The Product label has a pictorial representation of a XXXXX. 2. ...

20 June 2002 GST/HST Interpretation 37564- Electronic Payment of Parking Tickets Unedited CRA Tags ETA 123(1) financial service, (a); ETA 123(1) financial service, (n); ETA 123(1) financial service, (t) SOR/91-26 4(2)(c) Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa, ON K1A 0L5 XXXXX XXXXX XXXXX XXXXX Case Number: 37564 Attention: XXXXX June 20, 2002 Subject: GST/HST INTERPRETATION Electronic Payment of Parking Tickets Dear XXXXX: Thank you for your letter of October 1, 2001, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the internet payment of parking tickets as proposed by your client. ... Information from conversation April 11, 2002: •   The convenience fee is for the payment of parking ticket fines. ... From the information provided it appears that para. 123(1)(a) — "the... transfer of money, whether effected by the exchange of currency, by crediting or debiting accounts or otherwise," — of the "financial service" definition applies where your client in fact transfers the money from the ticket payor to the municipality. ...

23 September 2002 GST/HST Interpretation 34134- Web Site Design Unedited CRA Tags ETA 142(1)(g); ETA 165; ETA Sch VI, Part V, 7 Excise and GST/HST Rulings Directorate Place de Ville, Tower A, 15th floor 320 Queen Street Ottawa ON K1A 0L5XXXXX XXXXX XXXXX XXXXXXXXXX Case Number: 34134XXXXXSeptember 23, 2002 Subject: GST/HST INTERPRETATION Web Site Design Dear XXXXX: Thank you for your letter of XXXXX, and the facsimile dated XXXXX XXXXX, sent by XXXXX, concerning the application of the Goods and Services Tax (GST)/Harmonized Sales Tax (HST) to the supply of Web site design. ... The following facts were presented in your letter. •   XXXXX is a GST/HST registrant that develops Web sites for a company who is resident of the United States (U.S.) •   The supply of the service of developing the Web sites is performed in XXXXX. •   After a Web site is designed, XXXXX sends the site and its complement of web pages electronically to the non-resident company. ... The information to be included in the credit note is as follows: •   a statement that the document is a credit or debit note; •   your business or trading name and your Business Number; •   the customer's name or trading name; •   the date on which the note is issued. ...