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The King, 2023 TCC 93-- summary under Subsection 141.01(4) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(4) Amex did not make “free” supplies of rewards to credit card holders but instead were made for consideration and for the purpose of facilitating its exempt credit card business The Minister denied the input tax credit (“ITC”) claims of Amex Bank of Canada’s (“Amex”) for its 2002 to 2012 taxations years for GST/HST paid on expenses arising in connection with the administration and operation of Amex’s Membership Rewards Program (“MRP”), including expenses incurred for the purpose of providing its cardholders who were members of the MRP (“Members”) with rewards on the redemption of points earned by them mostly through making purchases on their cards. ...

Here, regarding s. 6(1)(b)(vii) “its wording requires that the employee be travelling away from the employer’s establishment … [whereas h]ere, Burnaby City Hall has no connection to the employer’s establishment so the allowance received by Mr. ...

Commissioners for His Majesty's Revenue and Customs v Arrbab, [2024] EWCA Civ 16-- summary under Regulations/Statutory Delegation Summary Under Tax Topics- Statutory Interpretation- Regulations/Statutory Delegation restrictive interpretation of power accorded in subordinate legislation to amend the primary legislation Section 124 of the Finance Act 2008 ("FA 2008") provided inter alia that Treasury could by statutory instrument make an order in connection with appeals against HMRC decisions which amended the provisions of any Act, provided that a draft of the order had been laid before and approved by resolution of the House of Commons. ...

Section 206 provides that there can be such an amendment “provided doing so does not delay the proceeding and is not contrary to the interests of justice” but that “the amendment of a pleading must not result in an entirely new application having no connection with the original one.” ...

Canada, 2001 FCA 159-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply charges to fleet operators for insurance and licences were taxable resupplies The appellant orally contracted for the services of owner-operators of trucks in connection with its freight transportation business, and provided them with the option of acquiring motor vehicle and motor carrier licences ("licences") and access to the benefit of insurance coverage under policies issued to Vanex, as well as oil and fuel at discounted rates. ...

Agence du revenu du Québec, 2023 QCCQ 10239, aff'd 2025 QCCA 234-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) deductible interest on loss consolidation loans reduced from 14% to 8.75% In connection with a September 2009 loss consolidation transaction between a “Lossco” in the Brookfield group (“BRPI”) and its “Profitco” subsidiary (“BEMI”): Two Ontario Newcos, which had been incorporated with nominal share capital by the Brookfield public-company parent of BRPI (“BAMI”), were lent $2.25 billion and $0.525 billion, respectively, by BRPI pursuant to unsecured demand notes bearing interest at 14%; Each Newco used the loan proceeds to subscribe for non-cumulative preferred shares of BRPI that did not provide any schedule for the payment of dividends thereon; On the same day, the Newco shares were sold for a nominal amount by BAMI to BEMI and the Newcos were wound up into BEMI, so that BRPI held $2.275 billion of loans in its subsidiary (BEMI) and BEMI held $2.275 billion of preferred shares of its parent (BRPI); and The loans were left outstanding for approximately five months, then: BRPI declared and paid a dividend on the preferred shares to fund the payment of all the accrued interest on the loans, and those shares and loans were immediately redeemed and repaid by way of set-off. ...

., the doing of something in connection with the establishment of a commercial activity) (para. 46), so that there was a deemed acquisition by the Appellant of the property. ...

The draft RVO also provided that such taxes would include any taxes related to debt forgiveness arising from or in connection with the consummation of the transaction. ...

., to deter another bidder and to earn a profit if the bid failed) is not relevant to this issue” (para. 63); and “The Fees were linked to Falconbridge’s operations as a nickel mining company”, which “required access to ore deposits” so that they were received “in the course of” those activities (a phrase which was essentially equated with "in connection with") (para. 70); furthermore, “the Fees were linked to an acquisition of shares that had the capacity to produce property income” so that they were “also received in the course of earning income from property” (para. 71). ...

The Crown did not challenge this finding in connection with the appeal by the taxpayer of other Tax Court findings to the Federal Court of Appeal. ...