The appellant, whose only "activity" was holding the shares of a wholly-owned subsidiary ("Pay Linx"), acquired property and services to maintain the register of its shareholders, and to facilitate trades of its shares on the TSX, as well as receiving legal services, and wire services to issue press releases. It claimed input tax credits on the basis that it incurred these expenses in relation to its shares of Pay Linx.
Little J. denied the claim on the basis that the property and services acquired by the appellant related to its own activities (which were not commercial activity) and not to the activities of Pay Linx.