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      … if the Appellant’s appeal is successful, it will establish the principle that members of the OSCA engage in a “financial service” for purposes of the ETA which are “exempt supplies” not subject to tax under the ETA with the result that the OSCA members would not be entitled to claim input tax credits for GST paid on purchases made in connection with provision of the exempt services.   5.      ...

This decision could have had a significant impact on the deduction that support recipients could claim under paragraph 18(1)(a), since paragraph 18(1)(c) stipulates that no expense may be deducted "in connection with property the income from which would be exempt". 33       To maintain the right to the deduction, Parliament amended the definition of "exempt income" [...] in subsection 248(1) to exclude the part of the support that is intended for children, even if it is now non-taxable. ...

He did not offer any compelling evidence showing that he was unable, for reasons related to his origin or language, to understand the consequences of his waiver or that tax officials tried to mislead him, threaten him or apply undue pressure in connection with the waiver. ...

They were directors in law only because of their family connection to Eugene Fitzgerald. ...

(c)  the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply;   Thus, the supply of real property is a supply made in the course of a commercial activity, provided that it is not an exempt supply ...

A subcontract to NTT Network Corp. for $15,000.00 for work described as: Installation of 6 Compaq servers Fibre Optics cable connection 600 ft. ...

Harkins produced it to CCRA in connection with his 1997 tax assessment. [11]     Mrs. ...

Analysis and conclusion [10]     Subsection 170(2) of the Excise Tax Act (the "ETA") provides: 170(2) Further restriction- In determining an input tax credit of a registrant, no amount shall be included in respect of the tax payable by the registrant in respect of property or a service acquired, imported or brought into a participating province by the registrant, except to the extent that a)          the consumption or use of property or services of such quality, nature or cost is reasonable in the circumstances, having regard to the nature of the commercial activities of the registrant; and b)          the amount is calculated on consideration for the property or service or on a value of the property that is reasonable in the circumstances. [11]     Section 123 of the ETA defines "commercial activity" as follows: "commercial activity" Commercial activity of a person means (a)         a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b)         an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c)         the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply; [12]     Paragraphs 50, 54 and 55 of the decision of the Supreme Court of Canada in Stewart v. ...

However, in a recent judgment this court undertook to reject that approach, and I take the liberty of citing what I then wrote in this connection in the reasons submitted for the court. [7]      Then at paragraph 15 he said: The function of an appellate judge is thus not simply to consider whether the Minister was right in concluding as he did based on the factual information which Commission inspectors were able to obtain and the interpretation he or his officers may have given to it. ...

Southen's argument was simply that after he and his wife stopped using the property as their residence, the ownership and subsequent sale of it was a business matter, and so the loss that he suffered in connection with it, as calculated above, was a business loss to be deducted in computing his income for the years in question. ...