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The Queen, 2019 TCC 149-- summary under Subparagraph 3(c)(iii) Summary Under Tax Topics- Excise Tax Act- Regulations- Input Tax Credit Information (GST/HST) Regulations- Section 3- Paragraph 3(c)- Subparagraph 3(c)(iii) statement of terms of payment was implied The appellant, which was seeking to develop one of its residential rental properties as a commercial storage site, received services from individuals or companies associated with the Foley family in connection with such property development. ...

The taxpayer borrowed a larger sum in connection with subscribing for and acquiring common shares of Vidabode in order inter alia to fund the repayment by Vidabode of the GE Capital loans. ...

The Queen, 2020 TCC 34-- summary under Subsection 261(3) Summary Under Tax Topics- Excise Tax Act- Section 261- Subsection 261(3) In connection with a purchase of a dental practice (by the taxpayer, or by a partnership between him and the vendor – those facts are not clear), on February 29, 2012, the taxpayer paid the vendor $85,013.50 in HST in addition to the purchase price and, following a change in accountants, filed GST/HST general rebate application dated February 12, 2016 seeking a rebate of tax paid in error in the amount previously paid. ...

They described the conduct of the assistant director in connection with their complaints as harassing, and claimed that the award constituted damages for personal injury and violation of their rights under their collective agreement, and should be treated as a personal injury award that was non-taxable under s. 81(1)(g.1). ...

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. ...

The King, 2023 TCC 93-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) costs of Amex’ points program were inputs to its exempt credit card revenues, and did not generate ITCs The Minister denied the input tax credit (“ITC”) claims of Amex Bank of Canada’s (“Amex”) for its 2002 to 2012 taxation years for GST/HST paid on expenses arising in connection with the administration and operation of Amex’s Membership Rewards Program (“MRP”), including expenses (”Reward Expenses”) incurred for the purpose of providing its cardholders who were members of the MRP (“Members”) with rewards on the redemption of points earned by them mostly through making purchases on their cards. ...

Hill J found that most of the documents before her for which the taxpayer claimed solicitor-client privilege were not protected from production to the Crown primarily on the following grounds (at paras. 74-75): First, in some instances the document on its face contains insufficient information, because neither the author nor the recipient is listed and there is no clear connection to the provision of legal advice. ...

After finding that s. 95(2)(b)(i) did not apply to include the fees of the US Affiliates in computing the foreign accrual property income (FAPI) given the reciprocal nature of the services, Bocock J found, in the alternative, in light of the broad meaning of “in connection with” and the important and ongoing role which the R&D services played in meeting the immediate demands of smartphone customers (e.g., teleco carrier testing and bug fixes), that the exclusion in s. 95(3)(d) applied. ...

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. ...

The litigation between the appellant and Starwood in connection with the failure of the sale to close was settled in 2018 by the agreement of the appellant to pay $450,000 to Starwood (plus return the $360,000 deposit) pursuant to a settlement agreement that provided inter alia that Starwood was to assign to the appellant all its rezoning application plans and reports. ...