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[emphasis added] [31]   In connection with determinations under IRPA ss 96-98, the SIO must be sensitive to the Maldonado Principle that a refugee claimant’s testimony is presumed true and credible absent any reason to discount or disbelieve it: Maldonado, above at para 5. ...

In that decision, the Federal Court held that “[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition” (at para. 78). ...

They do not agree on whether it was a taxable or an exempt supply. [32]   Indeed, the issue before the Court is whether CanLII is entitled, pursuant to subsection 169(1) of the ETA, to claim ITCs in respect of the GST it paid to the third-party service providers. [33]   Subsection 169(1) reads as follows: Input Tax Credits General rule for credits 169 (1) Subject to this Part, where a person acquires or imports property or a service or brings it into a participating province and, during a reporting period of the person during which the person is a registrant, tax in respect of the supply, importation or bringing in becomes payable by the person or is paid by the person without having become payable, the amount determined by the following formula is an input tax credit of the person in respect of the property or service for the period: A × B where A is the tax in respect of the supply, importation or bringing in, as the case may be, that becomes payable by the person during the reporting period or that is paid by the person during the period without having become payable; and B is (a) where the tax is deemed under subsection 202(4) to have been paid in respect of the property on the last day of a taxation year of the person, the extent (expressed as a percentage of the total use of the property in the course of commercial activities and businesses of the person during that taxation year) to which the person used the property in the course of commercial activities of the person during that taxation year, (b) where the property or service is acquired, imported or brought into the province, as the case may be, by the person for use in improving capital property of the person, the extent (expressed as a percentage) to which the person was using the capital property in the course of commercial activities of the person immediately after the capital property or a portion thereof was last acquired or imported by the person, and (c) in any other case, the extent (expressed as a percentage) to which the person acquired or imported the property or service or brought it into the participating province, as the case may be, for consumption, use or supply in the course of commercial activities of the person. [34]   Therefore, CanLII will be entitled to ITCs if it acquired property or a service for consumption, use or supply in the course of its commercial activities. [35]   Commercial activity is defined in subsection 123(1) as follows: 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. [36]   In the present case, the respondent argues that by virtue of section 10 of Part VI of Schedule V of the ETA (which section is reproduced above in paragraph 3 of my Reasons) CanLII’s business involved the making of exempt supplies. [37]   The respondent is of the view that all or substantially all the services supplied by CanLII were supplies made for no consideration. [38]   In the respondent’s oral argument, counsel stated that the Federation made discretionary payments that did not fall within the definition of “consideration”, as they were not made pursuant to a legal obligation. ...

He submits that the evidence demonstrates that he has maintained a significant connection to the U.S. during his period of medical treatment despite his lengthy presence in Canada; that any failure to fully disclose his circumstances to the BSOs was inadvertent or arose due to his misunderstanding the BSOs’ questions; and that the BSOs were familiar with his circumstances as a result of his regular crossings. ...

The provisions of these two paragraphs are as follows: 18(1)   General limitations – In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a)   general limitation – an outlay, loss or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (b)   … … (h) personal and living expenses – personal or living expenses of the taxpayer, other than travel expenses incurred by the taxpayer   while away from home in the course of carrying on the taxpayer’s business; [22]   Section 248 of the Act defines “personal or living expenses” as follows: 248.(1) In this Act … “personal or living expenses” includes (a)   the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, [23]     In addition, under section 67 of the Act, a taxpayer may not deduct an “unreasonable”expense, even if the expense is otherwise deductible under the Act. ...

This is a pure question of fact, and of course the Officer is entitled to draw inferences in this connection as happened here. [34]   Moreover, and as noted above, on judicial review I am instructed to take a respectful view of the Decision (Vavilov, at para 12), and when I do, I find support for the Officer. ...

Victus Academy paid the City for the use of the facilities, its teachers, and the two third party businesses that provided services in connection with the school day hockey program. ...

In the Proteus Contract, Scannar agreed to pay, and in fact paid, a research and development fee in the amount of $25,000,000, which was payable as to $17,700,000 by cheque, and as to $7,300,000 by delivery of a promissory note, in consideration for Proteus’ agreeing to carry on scientific research and experimental development on behalf of Scannar in connection with certain laboratory rapid diagnostic products. 8. ...

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

In this connection, the company shall table at the closing the form prescribed under said subsection 194(4), being Form T2113, and an information return, being Form T2114 and all corresponding Province of Quebec, Department of Revenue Forms, all duly completed for filing with the Minister of National Revenue and shall immediately forward such forms to such Minister by registered mail, return receipt requested. ...