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It was one of the first companies to work with Bell Canada (“Bell”) in Ontario and Quebec, reselling the newly-available, high-speed internet connections to the public. ...

Questions were also raised regarding a number of irregularities in connection with the holding of the 2004 festival. ...

(d)         acting as a selling agent in connection with the distribution of mutual funds. ...

Also material is that it did provide to Hartford a service in connection with the collection of premiums and the settlement of claims. ...

ANALYSIS [15]          In considering whether the Appellants are subject to GST on the transfer of Lot 3 and Lot 5 we must examine certain definitions in the Act. [16]          The relevant definitions found in subsection 123(1) of the Act read as follows:                 "supply" means, subject to sections 133 and 134, the provision of property or a service in any manner, including sale, transfer, barter, exchange, licence, rental, lease, gift or disposition;                 "taxable supply" means a supply that is made in the course of a commercial activity;                 "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; "individual" means a natural person; [1]                 "person" means an individual, a partnership, a corporation, the estate of a deceased individual, a trust, or a body that is a society, union, club, association, commission or other organization of any kind;                 "exempt supply" means a supply included in Schedule V; "business" includes a profession, calling, trade, manufacture or undertaking of any kind whatever, whether the activity or undertaking is engaged in for profit, and any activity engaged in on a regular or continuous basis that involves the supply of property by way of lease, licence or similar arrangement, but does not include an office or employment; "builder" of a residential complex or of an addition to a multiple unit residential complex means a person who (a) at a time when the person has an interest in the real property on which the complex is situated, carries on or engages another person to carry on for the person (i) in the case of an addition to a multiple unit residential complex, the construction of the addition to the multiple unit residential complex, (ii) in the case of a residential condominium unit, the construction of the condominium complex in which the unit is situated, and (iii) in any other case, the construction or substantial renovation of the complex, (b) acquires an interest in the complex at a time when (i) in the case of an addition to a multiple unit residential complex, the addition is under construction, and (ii) in any other case, the complex is under construction or substantial renovation, [17]          It will be noted that the definition of "business" states that business is defined to include an undertaking of any kind. ...

If Enterprises is found to be a personal services business, then it is not entitled to the small business deduction and the expenses to earn the income are disallowed by the provisions of paragraph 18(1)(p). [3]            Section 125(7) is a definition section and defines "Active Business" as: "active business carried on by a corporation" means any business carried on by the corporation other than a specified investment business or a personal services business and includes an adventure or concern in the nature of trade; and it also defines "Personal Services Business" as: "personal services business" carried on by a corporation in a taxation year means a business of providing services where (a)    an individual who performs services on behalf of the corporation (in this definition and paragraph 18(1)(p) referred to as an "incorporated employee"), or (b)    any person related to the incorporated employee is a specified shareholder of the corporation and the incorporated employee would reasonably be regarded as an officer or employee of the person or partnership to whom or to which the services were provided but for the existence of the corporation, unless (c)    the corporation employs in the business throughout the year more than five full-time employees, or (d)    the amount paid or payable to the corporation in the year for the services is received or receivable by it from a corporation with which it was associated in the year; [4]            Paragraph 18(1)(p) sets out the limitation re personal services business expenses and reads: (p)    Limitation re personal services business expenses- an outlay or expense to the extent that it was made or incurred by a corporation in a taxation year for the purpose of gaining or producing income from a personal services business, other than (i)     the salary, wages or other remuneration paid in the year to an incorporated employee of the corporation, (ii)    the cost to the corporation of any benefit or allowance provided to an incorporated employee in the year, (iii) any amount expended by the corporation in connection with the selling of property or the negotiating of contracts by the corporation if the amount would have been deductible in computing the income of an incorporated employee for a taxation year from an office or employment if the amount had been expended by the incorporated employee under a contract of employment that required him to pay the amount, and (iv) any amount paid by the corporation in the year as or on account of legal expenses incurred by it in collecting amounts owing to it on account of services rendered that would, if the income of the corporation were from a business other than a personal services business, be deductible in computing its income; [5]            Stuart Ross ("Ross") is the sole owner and officer of Enterprises. [6]            It is common ground that: (a)           at all material times Ross was a "specified shareholder" of the Appellant within the meaning of that term in subsection 248(1) of the Act; (b)            Enterprises did not employ more than five full-time employees during the years under appeal; (c)            Ross performed services (the "Services") on behalf of Enterprises for Clearly Canadian; (d)            Enterprises and Clearly Canadian were not associated during the years under appeal; (e)            during the years under appeal Ross was a director and the Executive Vice-President of Clearly Canadian; [7]            This appeal is the third appeal before this Court wherein the Minister alleged that a corporation dealing with Clearly Canadian was a personal services corporation. ...

There are also a number of cases where this Court used the latitude provided for by paragraph 118.2(2)(n) to interpret it in a manner which would allow the deduction, despite the absence of the conventional situation of a pharmacist filling out a prescription. [12]          In this connection I refer to the case of Frank v. ...

A commercial activity is defined as follows in subsection 123(1) of the ETA: "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... [30]          Thus, the reasonable expectation of profit test is specifically included in the legislative provision that defines a commercial activity. ...

Also the farming operation was adversely affected by the matrimonial breakup. [17]     The custom operation with Husky clearly has several farm connections. ...

She spent upwards of 60% of her time in connection with her work as chairperson of the OHSC. [3]            Part II of the Canada Labour Code contains extensive provisions relating to the safety and health of persons employed in a federal work, undertaking or business. ...