Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160 -- summary under Subparagraph 1(a)(ii)

CIBC’s interchange fees from a non-resident credit-card processor were not zero-rated as relating to the loans effectively made to its Cdn. cardholders

In 2001 (before the three annual fiscal periods in issue) the appellant (CIBC) outsourced part of its Visa-card transaction processing and payment...

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Words and Phrases
relates to lending debt primarily
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 280 - Subsection 280(1) - Paragraph 280(1)(a) due diligence defence established based on reasonable filing position 55