The appellant (CanLII) was a not-for-profit corporation that operated an open-access virtual law library. Its sole member was the Federation of Law Societies of Canada (Federation), which collecting fees from 14 law societies in Canada to fund all of CanLII’s operating budget of around $3 million per annum, and claimed input tax credits of over $0.7 million for the 27 month period in issue on its taxable purchases. The Minister disallowed these ITCs on the basis that CanLII provided its service for no consideration and, therefore, provided an exempt supply pursuant to Sched. V, Pt. V, s.
