Tax Court of Canada

Requirements of personal services business were not met

Tax - Income tax - Business and property income

Award contributed to costs incurred by taxpayer without being extravagant or punitive to Minister

Tax - Income tax - Administration and enforcement

Beneficial owner of property qualified as builder to apply for and receive rebate

Tax - Goods and Services Tax - Rebates

Corporation’s tax debt was not executed and returned unsatisfied

Tax - Income Tax - Tax Avoidance

Gift certificate for purpose of s. 181.2 of Excise Tax Act must be form of property

Tax - Goods and Services Tax - Supply

Taxpayer’s undertaking was entirely commercial

Tax - Income Tax - Business and Property Income