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. … If the payments were remuneration payable to Ms. Kirsten for her services, subsection 56(2) would not require the payments to be taxed in the hands of Mr. ...

Finally, although both the parties might "... have agreed that Ticketnet was liable to pay $2 million to Air Canada for services rendered, a liability that terminated on the good faith non-acceptance of the software... this is not what the contract provide[d]". ...

" and that this condition was satisfied here given that the taxpayer's exercised control over Holiday 80. ...

Before going on to find that s, 186(2) also applied so as to provide input tax credits for GST on the fees incurred by the appellant in connection with this listing, C Miller J found that s. 186(1) applied to deem the appellant to incur the fees for use in its commercial activities, stating (at paras. 16-17): The facts are quite clear – the listing services were acquired so that Stantec could complete its deal to own all the shares of the company resulting from the merger of Keith Companies and Stantec California. ...

See summary under s. 163.2(1) – culpable conduct. ...

Furthermore, such expert erred in treating retail sales by Infosource as a relevant comparable for valuing the licences here as they essentially had been acquired on a wholesale basis – so that the modest price paid to Infosource represented the licences' fair market value. ...

. … The second part of the test… determined by an objective evaluation of the specific facts and circumstances of each case in relation to appropriate jurisprudence, having regard to whether the taxpayer acted in accordance with reasonably acceptable principles of commerce and business practices. ...

" Similarly, Lord Millet stated (at 418 WLR): Once the taxpayer has identified the payment the question to be asked is: did he obtain anything- anything at all – used or to be used for the purposes of his business in return for that payment? ...

., that it was not one or the other of those things, cannot be” – as was the case here as the taxpayer’s debenture purchase had effectively been admitted not to be an investment. ...

. … At the end of the day, however, it falls to Parliament to enact the law, the courts to interpret the law and the CRA to enforce the law…. ...