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For example … there may be an interrelationship between the Appellant’s acquisition of the investment management services and its resupply of such services to the Pension Plans. … The Court cannot answer the Rule 58 Question … in a factual vacuum. ...

Such evidence must clearly establish that the “outsider” … has “effective” or “independent” management and control. … Ms. ...

[T]he wide scope of "legal advice" … and the concept of "continuum of communications" must be taken fully into account. If the dominant purpose of the communication is … to settle the instructions to the lawyer then … that communication will be covered by LAP. ... The purpose of the email was modest: it was intended to show that … not all of the executives at CAA shared the approach suggested by Mr Haines' earlier email. ...

In finding that this amount was deemed by s. 182 to include GST, Favreau J stated (at paras. 65-67, TaxInterpretations translation): [T]he conditions for the application of section 182 … are met in this case. There was a modification of an agreement for the making of a taxable supply in Canada to a person and an amount was paid to the registrant otherwise than as consideration for the supply. … Unfortunately for the appellant, the rules provided under paragraph 182(1)(b) … applied irrespective whether McKesson had claimed an input tax credit respecting the damages paid. ...

In addition to accepting their explanation of changed personal circumstances for the sale, Spiro J. noted (at paras. 34-35) that their professed intention of holding for the long term as their home was corroborated by their idiosyncratic choices in customizing the home’s details: … Rather than installing multiple televisions, the Appellants installed multiple fireplaces. This strongly suggests that they built the home only for themselves. … [T]he Appellants left nothing for a potential purchaser to customize. … The fact that the Appellants finished everything to their own personal taste strongly suggests that they built the home only for themselves. ...

Smith J found that the receipts invalid, stating (at paras 31, 32 and 45): … [A] receipt is a written document delivered in exchange for the receipt of money, goods or services, reflecting the actual amount of money or the fair market value of the property or services received. It follows that a document, though it bears the title “receipt” or “charitable receipt” …, may not be treated or accepted as such if it does not accurately reflect the money paid or the fair market value of the property or services actually provided in exchange. … [A]lthough the donation receipts in question are described as “official receipts” …, they are not in fact receipts as that term is ordinarily understood. ...

. … The taxable supply that triggers payment (and the duty to pay tax) was never provided because the agreement that contemplated it was disclaimed. ... If payment must be deemed to have been made and taxes collected, it stands to reason that the triggering event be the payment of the damages that replace what would otherwise have been paid. … Conversely, what the ARQ proposes – that the payment be deemed to have been paid years before- would create a fiction that is entirely arbitrary. ...

Katsikonouris, [1990] 2 S.C.R. 1029 …. See summary under Sched. V, Pt. II, s. 1 – home care service. ...

He further rejected Pangaea’s submission that, as it had disposed of its veto right, the exclusion from the definition for an agreement that disposes of the taxpayer’s property applied, stating (at para. 62): I find that there is no evidence of a conveyance or disposition of the Appellant’s veto right — even if it can properly be characterized as “property”. … [T]here was no evidence of an assignment of the veto right to a third party. ...

Because it is not at all clear whether the Letter was directed to the Respondents individually or their connected entities, the first requirement of section 231.7 … for obtaining a compliance order has not been satisfied …. ...