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First, and most importantly, it is uncertain whether the chargeable event – redemption of a credit by viewing or downloading a document- will ever occur. … Secondly, it is not clear when redemption will occur, and by that time a number of features of the service might have changed. … [T]he possibility that the available documents might have changed appears to be a real one. ... [T]he elements of uncertainty… are sufficiently important to exclude the application of the prepayment rules contained in section 6(4) … and article 65.... of the Principal VAT Directive. If a prepayment is to be chargeable to VAT, it must relate to a particular supply of goods or services, with a direct link between the goods or services and the consideration paid in advance. … [W]e are of the opinion that the uncertainties in the present case are so material that the payment made when PAYG credits are purchased cannot be considered a prepayment towards the cost of any particular search. … … The supply is the viewing and downloading of documents, but it cannot be known at the time when the payment is made how many credits will actually be used and how many will remain unredeemed. ...

[N]o part of the Amount can be accurately characterised as earnings “derived … from … foreign service”, as opposed to earnings derived from foreign and Australian service. … [T]he Amount was incapable of apportionment as between earnings from foreign service, on the one hand, and earnings not from foreign service on the other because the agreed method of calculating that Amount did not allow for that distinction to be made. ...

Shelter [T]he persons involved lived under the same roof …. 2. Personal and sexual behaviour As for personal conduct, the appellant and madam conducted themselves as a married couple. They ate together 1 or 2 times per week. … It is to be noted that during the reconciliation efforts during the course of their therapy as a couple, more affection for each other was demonstrated (in particular, the walk hand-in-hand on Mount Royal). … As for sexual conduct … its absence during that period is to be noted. … 3. ... The child … They acted towards [their] child as persons living in a conjugal relationship and, during this period, projected towards this child the image of a united couple. … Respecting the criterion as to the presence or not of sexual relations, the jurisprudence has determined that, after a certain number of years of existence as a couple, the absence of such relations does not prevent the court from characterizing their relationship as marital or as conjugal. ...

Following the investigation, the three accused – Bouclair, its CEO and its Vice-President of Real Estate-- were charged jointly with various ITA tax evasion offences. ... The Court cannot condone such a practice. … Otherwise, the Jarvis protections simply melt away. ... Galiatsatos JCQ further noted that the ARQ auditor had already concluded before even seeing the false invoices that the VP Construction work had not been performed for Bouclair, and stated (at paras 315, 345, and 346): …[T]he … auditor… at that very early stage, had both subjectively [and]… objectively found evidence of tax evasion and set out from that point to build a case to establish the requisite intent, using the compliance audit mechanisms as a means of gathering evidence, even though she never intended the matter to be prosecuted criminally. … If Jarvis precautions had been on RQ’s mind at the relevant times, in my view, the matter would have – and should have – been referred for criminal investigation before even requesting and receiving the VP invoices…. … [B]efore even requesting to see the invoices, the potential for an innocent explanation was far-fetched. … …[T]he Court finds that the applicants’ constitutional rights were violated from the moment the auditor required production of the invoices for the VP Construction expenses. ...

Case C‑276/09 …). [I]t is for the referring court to ascertain whether, in the main proceedings, the NEC’s card processing service must be considered for VAT purposes to be a service which is ancillary to the sale of the tickets concerned or as a service ancillary to another principal service which is provided by the NEC to the purchasers of those tickets, which could be the reservation or the delivery of tickets for shows or other events and, therefore, forming with that principal service a single service with the result that that service must share the tax treatment of that principal service (see… Card Protection Plan … Case C‑349/96 …[and] Wojskowa Agencja Mieszkaniowa … Case C-42/14 …). ...

Lussier participated in entertaining activities … including a catamaran expedition …. ... The recreational activities were an opportunity to create or maintain relationships with advisors and brokers. … BMO had no say in BBA's choice of location for its convention, and the fact that it was held outside Quebec does not in any event have an impact on the TA criteria …. [T]he ARQ's … approach is somewhat penalizing and unfair to Mr. Lussier. ...

In particular, Moshinsky J noted (at paras. 309, 311 and 312): [T]he Second Amendment … had the effect that the interest that had accrued under the LNIA (approximately $286 million) was treated as not having accrued …. … I would not expect an independent party in the position of SAI to agree that the interest that had already accrued under the LNIA, which was a substantial sum, should be treated as not having accrued. … I would not expect independent parties in the positions of SAI and STAI to agree to the terms regarding benchmarks and the Premium. ...

Choice was a school which specially provided…both facilities and personnel for the care or for the care and training of persons suffering from the same mental handicap – ADHD – although only one or the other is required to meet the language of the provision. ...

On the trucks’ return to the company premises, they would sit there for 12 hours in order to permit the oils to settle out in their holding tanks – before the now, somewhat separated oils, were pumped out for further processing at the company’s premises with a view to their sale. Guimond JCQ found that, as this settling-out process was part and parcel of the process for purifying the oils and was more significant than the use of the trucks in transporting the oil, the trucks qualified as processing equipment under the Quebec equivalent of ITA s. 127(9) – qualified property – (c)(i). ...

The Court found that the appellant was a financial institution under s. 149(1)(a)(iii) as a person “whose principal business is as a … dealer in … financial instruments.” ... Turning to the meaning of “dealer,” the Court stated (at para. 29, TaxInterpretations translation): [T]he author Simon Labrecque properly states that the term “dealer” … relates to a person “whose business consists of dealing in financial instruments for its own account…” where this is for the purpose of profit. ... Furthermore, the role of the appellant – which was to the receive a cheque endorsed by the client, to whom it made the charges, followed by cashing it into its own bank account as endorsee – indicates that it was acting as a financial intermediary, the criterion identified by … Labrecque…. ...