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The supply of a financial service is an exempt supply for the purposes of the ETA, unless it is included in Part IX of Schedule VI (section 1 of Part VII of Schedule V). [16] No GST is collectible in relation to exempt supplies (section 165 of the ETA and the definitions of taxable supply and commercial activity in subsection 123(1) of the ETA) and no ITCs can be claimed for any GST paid on any goods or services acquired in connection with the making of exempt supplies (section 169 of the ETA and the definition of commercial activity in subsection 123(1) of the ETA). [17] Part IX of Schedule VI provides that certain supplies of financial services will be zero-rated supplies. ...

As for achieving the least expensive determination of the proceedings on their merits, the Respondents argue that, if a stay is not granted, the time, effort and expense that the parties would incur, in connection with the process of re-determining the compliance orders, may prove to be unnecessary if the SCC ultimately allows their appeal in whole or in part. [14] The Respondents contend that the delay necessary to resolve the SCC appeal will cause little prejudice to the Minister, as it will be relatively brief in comparison to the approximately eight years that these applications have been ongoing. ...

Ultimately, she did not see any connection between research and development and the mass production of jewelry where the primary focus was the aesthetic or visual appearance of the piece. (39) On cross-examination, Ms. ...

Moreover, the Second Review Reports reflect that the Officer considered not only the manner in which the Applicant had claimed that income but also the Applicant having provided limited services in connection with the rental of the boat. ...

There is a direct and immediate connection between the production of potash and the subsequent sale or disposition of that potash. ...

Grandmont maintains that the CRA’s Decision was incorrect given that the conclusions as to her ineligibility for CRB benefits disregarded the evidence provided in connection with her net income for 2020 and the reductions in her income for 15 CRB periods. [29] With respect, I do not share Ms. ...

She had also examined the electronic print records of the Appellant in connection with the assessment for the 2013 taxation year. [26] She explained the CRA followed a set of procedures for communicating with taxpayers in writing and that one of these procedures included the use of two “Print to Mail” sites located in Summerside, PEI and Sudbury, Ontario. [27] Ms. ...

According’ to the appellant, the reason for taking the title in his father’s name was that, ‘He was a business man and I was not and he looked after all the details in connection with the business.’’ ...

The Deputy Minister refused the claim on the ground that the respondent did not perform any manufacturing operation in connection with the precipitators. ...

The English Commission on taxation, which made its report in 1955, established six points (badges of trade): 1 the object of the sale: 2 the duration of ownership; 3 the number of similar transactions by the same person; 4 work done in connection with the property..; 5 the circumstances which caused the sale; 6 intention. 4.3.2 Canadian precedents consider almost the same factors: 1 intention; 2 the relationship between the transaction and the taxpayer’s business; 3 nature of the transaction and goods involved in it; 4 number and repetition of transactions: 5 the objects of the corporation. 4.3.3 In the case at bar, the factors to which the parties refer are the following: (a) intention: — the intention was to invest, says the appellant; —, the purchase was made with a view to resale, says the respondent; (b) duration of ownership: — the period of one month between purchase and sale is indicative, says the respondent, of commercial profit; — circumstances made it necessary to sell so quickly, explains the appellant; (c) partnership with Les Entreprises Marcal Inc: — Les Entreprises Marcal Inc has as its object the purchase and sale of land; the appellant does not hold shares in Les Entre- prises Marcal Inc; she is not a person connected with this company and is a legal person independent of the company; (d) number of transactions: — this is the appellant’s only transaction; according to the respondent, it is at least an adventure in the nature of trade (paragraph 139(1)(e)); (e) object of the sale: — by its nature a piece of land is usually an object of investment, especially if one plans to set up a campground on it-^however, it can be an object of trade if the investment was only a pretext, or if the buyer changed his mind too readily. 4.3.4 At first glance, what strikes the Board is perhaps this very readiness with which the buyers suddenly changed their minds about the campground and decided to sell. ...