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Agence du revenu du Québec, 2025 QCCA 745-- summary under Paragraph (c) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1)- Element B- Paragraph (c) inputs in physically converting 2 floors of a commercial building for residential use were not acquired in connection with the termination of a commercial activity St-Joseph incurred costs in converting the 1 st and 2 nd floors of a 12-storey mixed-use tower from commercial rental use into rental seniors’ residences (RSRs). It argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity, thereby entitling it to input tax refunds under the Quebec equivalent of ETA s. 169(1) – B(c). ...

Hogan J noted (at para. 52) that a "registrant can claim ITCs in respect of financial services contemplated by subsection 185(1) because the legislator chose to deem inputs for the purpose of financial service transactions to be inputs for the purpose of commercial activities” and further indicated that the words "relate to" indicate that the exception in s. 185(1) has a wide scope (only "some connection" is required: para. 50), rather than being restricted to financial services which are "incidental or ancillary to a registrant's primary business operations," as contended (at para. 46) by the Minister. ... In my opinion, this is a sufficient link or connection to justify a finding that the appellant's ABM operations "relate to" its other convenience store activities. ...

The term that is used to indicate a connection between the relevant amount of income, whatever that may be, and each of the United States tax and the Australian tax is 'in respect of'. ... No doubt, in each case the connection cannot be a distant, arbitrary or illogical one. But to the extent that it is necessary to identify the connection more precisely, that must be done in accordance with the provisions of the law of Australia. ...

In its relevant VAT return, BLP deducted the VAT paid on three invoices for professional services supplied to it by merchant bankers, solicitors and accountants respectively, in connection with the share sale. ... Under those circumstances the input tax charged on the advisory services supplied in connection with taking up the loan may be deducted, if it is attributable to taxable transactions. ...

Attorney General of Canada, 2018 QCCS 3381, aff'd 2020 QCCA 697-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault damages awarded against CRA for inter alia making unreasonable reassessments CRA made unreasonable reassessments with the knowledge that they were contrary to advice received from Rulings, offered in a settlement offer to settle elements that it knew it was going to abandon, failed to honour a commitment to give notice of the reassessments and delayed disclosures under the Access to Information Act process and made an inquiry with the Bermuda authorities that falsely stated that it was made in connection with a "criminal" investigation. In light of these and other failings by CRA, Hamilton JCS awarded the taxpayers approximately $4.8 million in damages comprised principally of interest that the large corporations were required to pay (i.e., 50% of the amounts) on the reassessments before they were reversed, a portion of the professional fees that were incurred in connection with the audit and, in the case of two of the individual taxpayers, $250,000 for damage to reputation (having regard to the false "criminal investigation" statement) and for stress, trouble and inconvenience. ...

After stating (in applying Hauser) that “the question of a person’s residency in one jurisdiction will be answered by examining the person’s connection to that jurisdiction and will not be influenced by evidence of links to a second jurisdiction” (para. 108) and finding that Mr. ... Sampson spent close to half of his time in British Columbia points to a clear personal connection with the province. ...

In 2013, in connection with their separation, they formed a holding company owned by Tremblay and Francoeur as to 70% and 30%, respectively. ... In confirming that Tremblay was taxable under the Quebec equivalent of s. 56(2) in connection with such occupancy by Francoeur, the Court stated (at paras. 18, 21-22, TaxInterpretations translation): The evidence indeed allowed the judge to conclude that, as early as 2013, the Company, acting at the time through the appellant, acquired the condominium so that Francoeur could reside there without signing a lease or paying any fees, which he did during the three years covered by the notices of assessment, and this with the continuous consent and/or authorization of the appellant, who controlled the Company notably due to his status as the majority shareholder of the corporation that owned all the shares of the latter. … [T]he appellant … stress[ed] that in the absence of a lease between the Company and Francoeur during the years in question, one cannot speak of a "transfer of rights" from the former to the latter. ...

Canada, 2001 DTC 5471, 2001 FCA 260-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) s. 248(10) assimilates a subsequent transaction to a common-law series if it has some connection with the series and is completed in contemplation thereof Rothstein JA found that transactions that had the effect of transferring properties with accrued losses to a partnership were a “common law” series, which he defined (at para. 24) as follows: [F]or there to be a series of transactions, each transaction in the series must be pre-ordained to produce a final result. ... As long as the transaction has some connection with the common law series, it will, if it was completed in contemplation of the common law series, be included in the series by reason of the deeming effect of subsection 248(10). ...

In 2007, FHI was approached on an urgent basis by Legacy to unwind the above "reciprocal loan arrangement" in connection with an imminent sale of the Washington hotel. ... Essentially the same reciprocal loan structure and mistaken unwinding strategy was used in connection with a Seattle hotel of Legacy. ...