Précis: This is a recently translated decision of Lamarre J. rendered before she was appointed Associate Chief Justice. Essentially the case dealt with 7 number companies which acquired software with the intention of starting net businesses which would provide financial simulation services. Each of the corporations claimed ITCs. The Minister denied the ITCs and imposed penalties under section 285 of the Excise Tax Act (the “ETA”) on the basis that they had never in fact entered into commercial activities since the web sites were never operative.
9114-4766 Québec v. R. - TCC: Solomonic decision - no ITCs but no penalty either for proto-businessesPlus >