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In connection with its appeal of the CRA denial of these rebate claims, CIBC brought a motion for its appeal to be allowed on the basis that the substance of the supply was already determined in the 2009 Decision. ...

Section 206 provided 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.” ...

Although the presentation of the RBC Reward Card triggered the Appellant’s entitlement to the interchange fees, I find that this connection is not sufficient for me to conclude that expenses incurred in the redemption of loyalty reward points earned from transactions involving non-resident merchant–acquirers were part of a taxable or zero-rated supply. ...

In connection with the second point, Gagnon J reviewed the jurisprudence under ss. 5(1) and 6(1)(b) and stated (at para. 72): The Court also believes the foregoing analysis supports that, without the exclusion of benefits under a RCA, the RCA contributions could be included in employment income of the Appellants and therefore the applicable tax treatment could not be decided as foreseen by another provision within the Act. ...

In particular, the evidence was consistent with the REIT having “raised money in its own capacity, and then used its money to invest in the LP” (para. 144) rather than having raised money on behalf of the LP (which the LP lacked the legal capacity to do), so that the evidence did not establish an implied agency; and there also was no evidence to suggest that an agency relationship arose for those periods by virtue of retroactive ratification by the LP as principal, given inter alia that at the time the alleged acts of agency were performed (in connection with the capital raises), the principal lacked the legal capacity to perform them and also lacked that capacity at any subsequent time of ratification. ...

Before concluding that the interchange fees were not zero-rated on the basis of the exclusion in VI‑IX‑1(a)(ii) for a service that “relates to (a) a debt that arises from … (ii) the lending of money that is primarily for use in Canada”, Sommerfeldt J found that: Regarding the “relates to” test, “there only needs to be ‘some connection’ between the interchange services and the debt described in the carve‑out, and the interchange services do not need to be ancillary or incidental to the debt” and the “ Slattery, Stantec and Miedzi Copper cases indicate that the phrases relating to, in relationship to, and, by extension, relates to, are to be given a wide or broad interpretation, and that a narrow view is to be avoided” (para. 54). ...

Agence du revenu du Québec, 2024 QCCQ 7814-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) a suspended Quebec police officer had not severed his Quebec ties when he started living (except when in Quebec) with his son in Ontario The taxpayer (Raiche) started living with one of his two sons in Petawawa Ontario when, in November 2015, he was suspended from his employment with the Quebec police force in connection with a criminal investigation of him. ...

" The partnership had acquired 200 acres of abandoned mountainous land to which it introduced deer and then employed a staff of around six people in connection with its activity of managing the land and organizing annual hunts for deer, for which it charged fees as well as selling the deer meat. ...

., “in relation to”, “with reference to”, or “in connection with”) the Minister’s decision to issue or confirm the NITR: Nowegijick at 39. ...

“Stewards,” being persons who had a commercial connection with such waste, were statutorily responsible for paying fees to SO to reflect their reasonable share of the associated costs. ...