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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. ...

“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. ...

. … [T]he connection between the use of the Services and the employee’s employment activities is even more tenuous when the employee’s family member receives the supply. ...

., cancellation) of the non-compete The taxpayer made a series of demands for parties to a non-compete agreement (that it had received in connection with its acquisition of a business) to comply with the agreement and, following negotiations and before the commencement by it of an action, it was agreed that it would be paid a lump sum in consideration for the cancellation of the non-compete agreement. ...

The case law requires a rational connection between the reasonably determined risk and the amount of the reserves. ...

La Reine, 2012 DTC 1076 [at at 2856], 2011 TCC 438 (Informal Procedure)-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) Archambault J. found that "bursary" amounts that the taxpayer received from the University of Laval in connection with his postdoctoral fellowship at that university were employment income rather than amounts described under s. 56(1)(n), because his work was in the nature of "employment" under Quebec civil law. ...

The Queen, 2011 DTC 1163 [at at 873], 2011 TCC 213-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure The taxpayer incurred legal and accounting fees in 1997 and 1998 of approximately $1.9 million in connection with a complicated reorganization of the manner in which it financed its investment in its US subsidiaries. ...

The Queen, 2011 DTC 1052 [at at 272], 2011 TCC 22-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 view to post-dissolution profit In connection with a limited partnership offering whose final closing was on December 31, 1993, the taxpayer bought units in the partnership for $18,000 and 18 common shares in a corporation for a dollar each. ...

The Queen, 2005 TCC 92-- summary under Business Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Business litigation support services provided by trustee for bankrupt financial institution were an "undertaking" The trustee in bankruptcy for a company ("Castor") which had essentially only engaged in investing in high-yield loans brought an action in its capacity of trustee for the Castor estate against the former auditors ("C&L") for $40 million in damages for breach of contract, and also began a "litigation support business" of providing assistance to most of the creditors (the "Participating Creditors"), including hiring professionals and experts, in connection with their action sounding in negligence against C&L for $800 million in damages. ...