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. … In my view, the interpretation of the contracts that is more consistent with the language of the contracts and the undisputed facts is that [such] payments were consideration paid by Amex to Costco, either for Costco entering into the Co-Branding Agreement, or specifically for the exclusivity provision. ...

. … As a matter of law it does not follow that, because the solicitor-client relationship is generally one of agency, all financial obligations incurred by a lawyer while providing legal services are incurred as agent of its clients. ...

. … While holding an ATP may exempt one from the application of the criminal law, it is not an “exemption” as contemplated by fiscal legislation…. ...

A submission of the appellant that he should not be liable for the unremitted GST of the company because the Minister took too long to assess (over 10 years), was rejected as being inconsistent with Addison & Leyen. ...

. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. ...

Canada, 2016 DTC 5006 [at 6525], 2015 FCA 288-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) inconsistent assessments of related taxpayers A Barbados corporation reported substantial profits from the sale of a herbicide to Canadian farmers, and deducted amounts paid to a non-arm’s length Canadian corporation (AgraCity – which was the taxpayer in the case) as service fees. ...

Leonati, [1996] 3 S.C.R. 458 … at paragraph 51). In the present case, all of the evidence necessary to consider the applicability of subsection 253(b) of the Act was adduced at trial and I am satisfied that the respondent will not be prejudiced by allowing the appellant to raise this argument; it was the respondent who raised at trial the issue of whether the appellant was carrying on business in Canada when the loss on the sale of shares was incurred ...

Of the sums collected, 40% were retained by it as the agreed consideration for its services, and the balance of 60% was paid to the physicians – except that the clinic deducted from this payment to an amount calculated as 7% GST on the (40%) value of its services. ...

Before so concluding, he stated obiter, respecting a Crown argument that it would have been beyond the competence of the Tax Court to (instead) declare that the options were invalid under Quebec law: [T]he role of the TCC, when confronted with an argument based on nullity in the context of an appeal under the ITA, cannot be assimilated to that of a Superior Court which has the power to “declare” a contract to be a nullity for all purposes pursuant to section 33, 35 and 142 of the Code of Civil Procedure … (see in comparison Markou v. ...

. … The judge… did not err in concluding that the supply is not a “financial service” since these [predominant] elements are properly characterized as a payment of an insurance claim for purposes of the inclusion in paragraph (f.1) and as an administrative service for the purpose of the exclusion in paragraph 4(2)(b) of the Regulations. ...