Onex Communications Corp. v. Commissioner of Revenue

Onex Communications Corporation (Onex) was formed in 1999 to design and sell integrated circuits for use in the telecommunications industry.1 Its efforts yielded the OMNI *644chip,2 early versions of which were produced, sold, and tested in 2001 before the device became generally available on the market in 2002. Able to accommodate thirty-two distinct voice channels on each of its 1,344 virtual circuits, a single OMNI chip could perform the work of ten chips made with prior technology. The product was revolutionary for its time and enabled substantial reductions in power use and system costs.

In…