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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. ...

The Queen, 2005 TCC 92-- summary under Paragraph 265(1)(f) Summary Under Tax Topics- Excise Tax Act- Section 265- Subsection 265(1)- Paragraph 265(1)(f) trustee's own suit and litigation support activity were related 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. ...

The Queen, 2005 TCC 92-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(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. ...

However, in connection with the sale in 2005, they discovered that (due to some communication difficulties relating to a change in the taxpayer's counsel) the corporate minute books recorded only one share as having been issued to each of them. ...

However, in connection with the sale in 2005, they discovered that (due to some communication difficulties relating to a change in the taxpayer's counsel) the corporate minute books recorded only one share as having been issued to each of them. ...

In finding that the appellant was entitled to input tax credits for GST on the fees incurred by it in connection with this listing, C Miller J found that ss. 186(1) and 186(2) both applied, so that the appellant was deemed to incur the fees for use in its commercial activities. ...

Before going on to find that s, 186(2) also applied so as to provide input tax credits for GST on the fees incurred by the appellant in connection with this listing, C Miller J found that s. 186(1) applied to deem the appellant to incur the fees for use in its commercial activities, stating (at paras. 16-17): The facts are quite clear – the listing services were acquired so that Stantec could complete its deal to own all the shares of the company resulting from the merger of Keith Companies and Stantec California. ...

The Queen, 2015 TCC 197-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply cellphone connection to a US telephone network, and transmission of call to Canada, were part of a seamless single supply to Canadian customer The appellant ("Telus") operated a wireless carrier business which entailed providing roaming airtime ("RAT") services to customers, with Canadian billing addresses, who while in the U.S. made long-distance call to Canada. ...

The Queen, 2015 TCC 197-- summary under Paragraph 142.1(2)(b) Summary Under Tax Topics- Excise Tax Act- Section 142.1- Paragraph 142.1(2)(b) cellphone connection to a US telephone network, and transmission of call to Canada, were part of a seamless single supply to Canadian customer The appellant ("Telus") operated a wireless carrier business which entailed providing roaming airtime ("RAT") services to customers, with Canadian billing addresses, who while in the U.S. made long-distance call to Canada. ...

Before completion of the IPO, the Fund, Trust, appellant and its general partner entered into a "Financing Agreement" in which they agreed that all financing expense in connection with the IPO, other than the underwriters' fee, were to be incurred on behalf of the appellant; and at the same time the appellant entered into an "Administration Agreement" with the Fund in which it agreed to administer the Fund and "as agent of the Fund" to pay for all outlays and expenses incurred by it in such administration. ...