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Of the sums collected, 40% were retained by it as the agreed consideration for its services, and the balance of 60% was paid to the physicians – except that the clinic deducted from this payment to an amount calculated as 7% GST on the (40%) value of its services. ...

Business In Motion International Corporation et al 2012 FCA 253] … However, that evidence was not before me. ...

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Before so concluding, he stated obiter, respecting a Crown argument that it would have been beyond the competence of the Tax Court to (instead) declare that the options were invalid under Quebec law: [T]he role of the TCC, when confronted with an argument based on nullity in the context of an appeal under the ITA, cannot be assimilated to that of a Superior Court which has the power to “declare” a contract to be a nullity for all purposes pursuant to section 33, 35 and 142 of the Code of Civil Procedure … (see in comparison Markou v. ...

Favreau J found that, notwithstanding the revocation of its revocation, the taxpayer was still a “registrant” – whose definition includes a “person who is required to be registered”- given that it still held equipment which it was seeking to sell (some of which it sold eight months’ later). ...

. … The judge… did not err in concluding that the supply is not a “financial service” since these [predominant] elements are properly characterized as a payment of an insurance claim for purposes of the inclusion in paragraph (f.1) and as an administrative service for the purpose of the exclusion in paragraph 4(2)(b) of the Regulations. ...

" More interestingly, he also found that in the absence of this Regulation, the service would have been exempt as being for the payment of insurance policy claims – notwithstanding that the Emergis service entailed the provision of taxable supplies described in para. ...

In the Tax Court below, Owen J ultimately found that the charges of Emergis to Great-West for this service were taxable under the Financial Services and Financial Institutions (GST/HST) Regulations, as they were "quintessentially administrative in nature," and also found that, in the absence of this Regulation, the service would have been exempt as being for the payment of insurance policy claims – notwithstanding that the Emergis service entailed the provision of taxable supplies described in para. ...

The Supreme Court further commented in discussing Olympia... and Impenco Ltd …: “If a specific provision exists which limits deductibility in respect of that purpose, then that should be the end of the matter.” ...

Brown J essentially indicated that it was reasonable for the CITT to consider that if the gloves were not covered by the specific paragraph dealing with clothing items, they should not be considered to be intended to be included in that heading, stating (at para. 50): It is reasonable to interpret that list item as stating exhaustively its own criteria — meaning, in this case, that if an article of clothing or accessories is to be classified in heading 39.26, it must be made by sewing or sealing sheets of plastic together [which was not the case for the goalie gloves]. ...