The appellant ("the College") was the statutorily designated professional governing body of teachers in Ontario. The Minister denied input tax credits that the College claimed in relation to its teacher accreditation process, on the grounds that the supply of teaching credentials was exempt pursuant to s. 20(d) of Part VI of Schedule V which, at the relevant time, read:
[A] supply of a service of providing information in respect of, or any certificate or other document evidencing, the vital statistics, residency, citizenship or right to vote of any person, the registration of any person for any service provided by the government or any other status of any person.
In granting the College's appeal, Jorré J noted (at para. 52) that the substance of what the College was charging for was evaluating and determining a candidate's eligibility as a teacher, and further stated (at paras. 56-57):
What is being done is evaluating a candidacy, and of course there is going to be some sort of record of that, but that is not what the paragraph in issue exempts.
On the face of the provision, what the paragraph would cover is someone asking, for example, for a copy of their birth certificate and paying a fee for it.
The words "in respect of", although broad, were insufficient to expand the kind of supply covered by the wording of s. 20(d) (paras. 62-64).