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The two bakery plants of the appellant in Toronto were staffed in significant part by temporary workers (“TWs”), who were sourced from third parties (the “Agencies”), which solicited for the TWs and directed them to the appellant. The appellant kept detailed records as to the hours worked by the TWs, which it provided to the Agencies for billing purposes, received invoices from the Agencies for the amounts identified in the invoices, and paid the Agencies therefor (including for HST) once it reconciled the amounts with its records.

The ARQ denied input tax credits claimed by the appellant (“Axamit”) for its 2015 year regarding GST charged by its landlord. Axamit did not provide any document specifically listed in the Input Tax Credit Information (GST/HST) Regulations to the ARQ during the audit or following its filing of its Notice of Objection. However, Gagnon J, after referring to the similar finding in CFI Funding that s.

A securitization trust (“CFI”) used a concurrent lease structure under which it became the concurrent (head) lessee of automobiles from automobile dealer and sublessor of the automobiles to the dealership customers, and financed the automobile dealers by prepaying rents under the head leas

After having filed returns for 1998-2001 that were essentially correct, the taxpayer submitted fraudulent T1 Adjustment Requests. Bocock J found that the Minister was justified in assessing s. 163(2) penalties for the misrepresentations on the Requests, and for assessing such penalties beyond the normal reassessment period.

The taxpayer's principal argument was that a T1 Adjustment Request is not a "return, form, certificate statement or answer" under the Act, as all these words have specific meanings. Bocock J stated (at para. 22):