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. … Once the general operation of the GST Act is understood in that way, it is apparent that there is no warrant in the text or policy of the GST Act for reading the reference in the special rule in s 40-35 to a supply of "residential premises" that is a supply "by way of lease" as referring to the supply which occurs at the time of entering into the lease but not as referring to the further supply which occurs by means of the lessor observing and continuing to observe the express or implied covenant of quiet enjoyment under the lease. ...

Although Mehjoo was resident in the UK, he might have been able to utilize a bearer warrant scheme ("BWS ") to avoid capital gains tax on his sale of shares of a UK private company on the basis that he was domiciled outside the UK. ...

" Similarly, Lord Millet stated (at 418 WLR): Once the taxpayer has identified the payment the question to be asked is: did he obtain anything- anything at all – used or to be used for the purposes of his business in return for that payment? ...

In finding that the deferral was not available, Feldman J.A. stated (at para. 16): The deeming provision in subsection 1(3) of the Securities Act states how "control" is defined for the purposes of the LTTA – on the basis of majority voting rights. ...

Kundahar J, speaking for a panel of two, found that Columbia did not have a permanent establishment, stating (at para. 14): If the petitioner has to purchase goods for the purpose of export, an obligation is cast…to see that the goods…[are] acceptable to the customer outside India…Otherwise, the goods…may not find a customer outside India…[A]ll those acts are necessary to be performed …before export of goods…That liaison office is established only for the purpose of carrying on business of purchasing goods for the purpose of export and all that activity also falls within the meaning of the words “collecting information “ for the enterprise. ...

. … It is however also necessary to take account of the call options purchased by ESIP out of the sum paid by UBS for its subscription for the shares. ...

. … Nothing in this case justifies a different decision [than in BBM]. ...

In addition, Interoil provided the shareholders with considerable information on the value of the new Arrangement and the value of the contingent resources; b) the Transaction Committee was independent, examined and endorsed the arrangement; c) the Fairness Opinion was independent and addressed the deficiencies of the previous fairness opinion; d) the shareholders had access to dissent and appraisal remedies and those who indicated they wished dissent rights were reduced from 10% on the first plan of arrangement to 1 % on the new plan of arrangement. ...

. … The tax motivation is a fact. This fact constitutes a backdrop to take into account respecting the trust and its actual activities. ...

[A] document … had to be signed by each of the employees, confirming that they were familiar with the obligation…. ...