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Technology will be considered "made available" when the person acquiring the service is enabled to apply the technology. … [P]ayment of consideration would be regarded as "fee for technical/included services" only if the twin test of rendering services and making technical knowledge available at the same time is satisfied. … [I]t is not even the case of the Assessing Officer that the assessee, i.e. recipient of services was enabled to use these services in future without recourse to BT Canada. ...

Lord Drummond Young found (at paras 28, 33) respecting this issue, that a supply of services was made only at the time that particular records were downloaded: [T]he search function cannot be considered an end in itself; it is no more than a means towards the customer’s ultimate end, namely viewing and downloading documents about the family that is being researched. …. … The consideration for the payments made by customers to obtain PAYG credits is the ability to view or download particular items on the taxpayer’s website, and does not extend to the general search facility that is available both to customers and to the public. … ...

Thus, the right to deduct VAT charged on the acquisition of input goods or services presupposes that the expenditure incurred in acquiring them was a component of the cost of the output transactions that gave rise to the right to deduct … [36] In this case, in view of the fact that, first, a share issue is an operation not falling within the scope of the [Directive] and, second, that operation was carried out by Kretztechnik in order to increase its capital for the benefit of its economic activity in general, it must be considered that the costs of the supplies acquired by that company in connection with the operation concerned form part of its overheads and are therefore, as such, component parts of the price of its products. ...

More than a decade later, HMRC assessed Mr Barker on the basis of a construction (the “post-death exclusion construction") of s. 28 of the Inheritance Tax Act 1984 which considered “that the words ‘at any time’ meant exactly what they said” (para. 93). ...

This precluded rollover relief to Mr Ellison (under s. 126-15 of the Income Tax Assessment Act 1997 (Australia)) unless, among other mooted requirements, it could be considered that the beneficial ownership of those shares had already been transferred to her by Sandini “because of” the consent orders. ...

Hydro-Quebec was quite willing to provide the information, but Roy J considered that this was irrelevant to whether he should grant the authorization. ...

It should be considered that the method to be adopted, if one must be adopted, is the latter method.... ...

But, in both decisions, the recognition that there were other sources of goodwill was itself considered in terms of the ability of those other sources to attract custom.... ...

Lévesque, J.C.Q. considered this issue to turn in part on whether the taxpayer’s consent was “free and enlightened” as required by Article 1399 of the Quebec Civil Code. ...

In affirming the ARQ position, Breault JCQ stated (at paras. 57, 68-69, TaxInterpretations translation): [I]n order for two housing dwellings or units in the same immovable to be considered a single housing unit for the purposes of TA section 274 (or ITA 54), they must be sufficiently integrated, one with the other, such that the owner can benefit from full enjoyment of the entirety. ...