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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). ...

In finding (at para. 66) "that FHA was administering a government program in respect of homemaker services," as required by the preamble to s. 13(1)(b)(ii), Paris J stated (at para. 66) that "it is only necessary, then, to show some connection between the B.C. ...

Shortly after the plaintiff received CRA's first correspondence on the matter, FMC sent him a retainer letter, which he signed, offering to advise him in connection with the proposed reassessment. ...

Bountiful had no connection to the Church of Latter-Day Saints (the LDS church had explicitly rejected some key practices in Bountiful, including polygamy), nor the Fundamentalist Church of Latter-Day Saints (there is no such organization, but rather only people who self-identify as members), nor any other identifiable organization. ...

Accordingly, s. 245(1) of the Act as it applied in June 1987 denied the deduction of the interest along with fees that were incurred in connection with entering into the transactions. ...

The Minister argued that Lavallee applied where law enforcement officials were seeking evidence of criminal wrongdoing, and not in connection with a regulatory compliance regime. ...