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Before going on to find that SEL did not qualify as a “college…of…a university” for UK VAT purposes, Patten LJ stated (at paras 64-65): The word "college" … denotes a group of people organised as an institution usually (but not necessarily) in the field of education. ...

. … It is customary that the required work is subject to detailed quotations which provided a template for detailed steps to be performed. ...

. … [T]he object of ETA section 223 and QSTA section 425 is to permit the recipient from whom the taxes are collected to be apprised of the amounts owing for the supply and what are the payments due for each of the taxes so as permit it to receive credits to which it has a right upon being invoiced for those taxes. ...

., address for invoicing and of electricity use, late payment identification and telephone number) for all its commercial customers who were charged the regular electricity rate – so that CRA could compare this information with what it had in its own files. ...

The corporation then sold this middle lot to an individual purchaser coupled with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

The corporation then sold this middle lot to an individual purchaser couple with a covenant that it would demolish this structure – which, however, it did not do until 45 days after closing. ...

. … The argument put forward by Bowman that they are “nothings” for Canadian tax purposes because they are merely reputational payments arising in a non-business circumstance may ultimately be upheld by the Tax Court, but it is not so clear at this stage as to render the CRA’s position unreasonable. ...

. … Moreover, the Tribunals looked to the substantive matters rather than theoretical factors, such as causative link and governing law, and so applied a practical approach. ...

Agence du revenu du Québec, 2018 QCCQ 5692, aff'd 2020 QCCA 1496-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) no abuse where individuals used PUC thrust upon them by an arm’s length investor (through PUC averaging) to subsequently strip surplus When the taxpayers’ corporation (“Opco”), a small business corporation, was in financial difficulty, a Quebec regional development fund agreed to inject equity capital in Opco on terms dictated by the fund – which entailed the fund investing in the common shares of Opco, so that the paid-up capital of the taxpayers’ shares was stepped-up from a nominal amount to $1.45 million (as a result of the aggregate class PUC being averaged on a per share basis). ...

The children … were declared as dependents of Mr. Rousseau for all the taxation years under litigation. ...