Subsection 4(1)
Person at Risk
See Also
Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10
The CIBC issued Visa credit cards and utilized a credit card payment system operated and managed by Visa Canada. Visa Canada essentially acted as...
Skylink Voyages Inc. v. The Queen, [1999] GSTC 119 (TCC)
The registrant served retail travel agencies by booking and purchasing airline tickets for the agencies' customers, which resulted in the receipt...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | 431 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | cancellation charges were consideration for a supply | 188 |
| Tax Topics - General Concepts - Agency | 205 |
Administrative Policy
24 January 2020 GST/HST Ruling 194625 - Services Provided to an Introducing Broker by a Carrying Broker
An Agreement between a carrying broker and the introducing broker contemplated that the introducing broker would effect all of its trades on all...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) | fees paid by an introducing broker to a carrying broker were GST/HST taxable | 495 |
Subsection 4(2)
Cases
Great-West Life Assurance Company v. Canada, 2016 FCA 316
The appellant ("Great-West") provided prescription drug plans to the employees of various employers. The claims were processed by a third party...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f.1) | “financial services” definition should be applied based only on the “predominant elements” supplied | 242 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply | characterization of single supply based on predominant elements | 203 |
See Also
Great-West Life Assurance Company v. The Queen, 2015 TCC 225
The appellant ("Great-West") provided prescription drug plans to the employees of various employers. The claims were processed by a third party...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f.1) | essential character of drug claim processing service was providing payment to the claimant | 306 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) | services described in (r.4) did not represent the essential character of drug claim processing service | 269 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) | essential character of drug claim processing service was providing payment to the claimant | 186 |
| Tax Topics - General Concepts - Payment & Receipt | constructive receipt by relieving obligation to pay pharmacist | 236 |
Drug Trading Company Ltd. v. The Queen, [2001] GSTC 48 (TCC) (Informal Procedure)
The registrant was a wholesaler of products to independent retail pharmacies operating under the "I.D.A." name, and also provided franchisor-like...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | 208 | |
| Tax Topics - General Concepts - Agency | 168 |
Administrative Policy
17 May 2012 Ruling 62492 [merchant Interac services]
An "Acquirer" is a connection service provider (i.e., it provides connection to the Interac network for the purpose of processing Interac direct...
19 July 2011 Headquarters Letter Case No. 111922
Corporation X administers insurance policies for large health plan providers (Providers) and independent employers (Employers) including employee...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service | 130 |
5 April 2006 Interpretation 60463
CRA discussed Shared Cash Dispensing (SCD) transactions allowing cardholders to access their accounts to withdraw cash at automated banking...
Paragraph 4(2)(b)
Cases
Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10
CIBC issued Visa credit cards and utilized the Visa payment system, which was “the set of instruments, procedures, rules, and technology by...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (t) | VISA provided core payment processing services that CIBC could not replicate that were more than merely administrative | 284 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (a) | VISA supplied a payment service to CIBC | 109 |
See Also
Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10
The CIBC issued Visa credit cards and utilized a credit card payment system operated and managed by Visa Canada. Visa Canada essentially acted as...
Healthcare Insurance Reciprocal of Canada v. The Queen, [2000] GSTC 50
Services provided by the appellant (“HIROC”) were found by Sarchuk J to be financial services which were not excluded by paragraph (t). HIROC...
Subsection 4(3)
Paragraph 4(3)(c)
See Also
Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10
The CIBC issued Visa credit cards and utilized a credit card payment system operated and managed by Visa Canada. Visa Canada essentially acted as...