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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]. ...

. … Words and Phrases deposit ...

. … [I]n civil law, it is quite possible to have an insurance contract without having a qualified or accredited insurer. ...

This reduction was effected by adjustment to the fee amounts and HST thereon in its books of account, but with no credit notes being issued by it – but it nonetheless claimed input tax credits equal to the HST amount on such fee reductions. ...

. … They reported “zero” income in both taxation years; they provided false information to the Minister to cause the partnership to be deregistered for GST and made no returns. ...

Three years later, the same accountant recommended that the taxpayers “restore the status quo ante " (para. 5), which they did by transferring the funds back to the corporation. ...

. … [A]s there is no valid appeal instituted before this Court under section 169 of the Act, the appellant's relief, if any, is most probably to be had by way of a declaration under subsection 18(1) of the Federal Courts Act. ...

When one has due regard to the departmental policy on the fair market value approach … it is clear that this policy approach says that no method should be discounted. ...

. … Consequently, the nullification pronounced by the Superior Court does not change the fact that the appellants received the amounts…in question and that they were amounts withdrawn from their respective RRSPs. ...