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However, he considered, given that there was no base erosion going on where the cross-border services were fully reciprocal (as here), that s. 95(2)(b)(i) should be interpreted as applying “solely to situations where a net positive amount is paid from Canada to the foreign affiliate” (para. 76) – so that s. 95(2)(b)(i) did not apply here given the greater value of the southbound services of BlackBerry. ...

. … Consistent with the statutory scheme, the Minister reserved the right to conduct an audit of the claimed ITCs to determine whether they related to an exempt or zero-rated supply, and to reassess accordingly. ...

IX, s. 1 by virtue of the exclusion in para. 1(a) thereof for a “service [that] relates to (a) a debt that arises from … (ii) the lending of money that is primarily for use in Canada”. ...

The use of an accountant as a representative in the course of obtaining legal advice or legal assistance for a client does not nullify otherwise privileged communications: Imperial Tobacco at para 71, citing Susan Hosiery …. ...

As … noted in City of Calgary, such supplies are parts or components of the single overall supply of electricity. ...

Before allowing the taxpayers appeal, Yuan J stated (at para. 41): I have difficulty imagining what better evidence the CRA could reasonably expect an applicant to produce as proof of filing where the application was submitted by regular mail …. ...

. … The Appellant continued to work outside the home after marrying CC and had no special training qualifying her to care for CC in a manner beyond the level of care that might be expected of any spouse. ...

He concluded (at para. 27): This is the type of situation … wherein a shareholder receives draws on the shareholder loan account throughout the year and then a dividend determination is made at some point for the year. ...

II, s. 9, Smith J stated (at para. 69, TaxInterpretations translation): [I]t is not sufficient … that the appellant's website inform the consumer of the need for a valid prescription. ...

The documents framed the optional term extension “as a separate pursuit … separate and distinct from the electricity supply contract” (para. 93). ...