Schedule VI

Table of Contents

Part I

Section 2

Cases

Hedges v. Canada, 2016 FCA 19

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Words and Phrases
exemption
Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality illogical to infer a tax benefit from illegal sales 153
Tax Topics - Statutory Interpretation - Headings heading did not contemplate illegal drugs 100

See Also

Hedges v. The Queen, 2014 TCC 270, aff'd 2016 FCA 19

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Administrative Policy

Excise and GST/HST News - No. 97 17 November 2015

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GST Memoranda Series 4.1 "Prescription Drugs and Biologicals" ETA - Schedule VI Part II

GST M 300-4-2 "Health Care Services"

Paragraph 2(a)

Administrative Policy

8 March 2018 CBA Commodity Taxes Roundtable, Q.3

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Paragraph 2(b)

Administrative Policy

Excise and GST/HST News - No. 101 March 2017

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The Prescription Drug List

Paragraph 2(e)

Cases

Patterson Dental Canada Inc. v. Canada, 2020 FCA 40

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply the single supply doctrine did not deem an anesthetic containing a drug substance to be that drug 143

See Also

Patterson Dental Canada Inc. v. The Queen, 2018 TCC 112, aff'd 2020 FCA 40

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Words and Phrases
drug

Administrative Policy

Section 6

Administrative Policy

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VII - Section 13 356
Tax Topics - General Concepts - Effective Date CRA allows immediate application of the new non-supply rules for human ova or embryos but won’t process rebate claims until passed 156
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service assimilation of provision of ovum or embryo to single supply at fertility clinic of institutional health care service 76

Part II

Section 9

See Also

Contact Lens King Inc. v. The Queen, 2020 CCI 71

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 286 - Subsection 286(1) failure to obtain and retain copies of customers' prescriptions did not comply with s. 286(1) 238

Section 11.1

See Also

Dr. Kevin L. Davis Dentistry Professional Corporation v. The Queen, 2021 TCC 25

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(b) invoices showing nil tax and not allocating between the included zero-rated and exempt supply complied with s. 3 369
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(5) agreement with the Canadian Dental Association was an exercise of discretion under s. 169(5) 273

Dr. Brian Hurd Dentistry Professional Corporation v. The Queen, 2017 TCC 142 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5 single supply by incorporated orthodontist of health care services 262
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service - Paragraph (h) single supply of orthodontic services by incorporated orthodontic practice qua health care facility 165
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of orthodotic service 87
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 1 - Institutional Health Care Service - Paragraph (b) orthodontic appliance was not a "medical prosthesis" 164

Section 24.1

See Also

Health Quest Inc v. The Queen, 2014 TCC 211 (Informal Procedure)

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Tax Topics - General Concepts - Onus mixed assumptions of fact and law 189

Section 32

See Also

Tremblay v. The Queen, [2001] GSTC 64 (TCC) (Informal Procedure)

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Section 33

Administrative Policy

Excise and GST/HST News, No. 104, July 2018

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Section 34

See Also

Buccal Services Ltd. v. The Queen, [1994] GSTC 70 (TCC)

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Section 37

Administrative Policy

Excise and GST/HST News - No. 97 17 November 2015

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Part III

Section 1

See Also

River Road Co-Op Ltd. v. The Queen, [1995] GSTC 34 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(2) 62

Administrative Policy

29 March 2017 Ruling 183173

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GST/HST Technical Information Bulletin B-110 Application of the GST/HST to the Practice of Acupuncture April 2017

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Paragraph 1(e)

See Also

Ike Enterprises Inc. v. The Queen, 2017 TCC 59

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Words and Phrases
confectionary
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(f) fried sticks were sold as snack and were not baked 233
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(h) granola in cereal aisle intended primarily as breakfast cereal 194

Paragraph 1(f)

See Also

Ike Enterprises Inc. v. The Queen, 2017 TCC 59

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(e) crystallized ginger sold as baking ingredient rather than candy 251
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(h) granola in cereal aisle intended primarily as breakfast cereal 194

Paragraph 1(h)

See Also

Ike Enterprises Inc. v. The Queen, 2017 TCC 59

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Words and Phrases
breakfast cereal
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(e) crystallized ginger sold as baking ingredient rather than candy 251
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part III - Section 1 - Paragraph 1(f) fried sticks were sold as snack and were not baked 233

Paragraph 1(k)

See Also

Hubka v. The Queen, [1995] GSTC 58 (TCC)

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Part V

Section 1

See Also

Muller v. Baldwin, L.R. 9 Q.B. 457

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Words and Phrases
exported

Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable, Q.9

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(2) - Paragraph 142(2)(a) Incoterms did not govern the place of delivery of goods 154

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 1

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94 CPTJ - Q. 1

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Section 2

Section 5

Administrative Policy

16 March 2018 Ruling 158124

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) USco’s use of a Canadian affiliate for substantial marketing support for web-delivered services did not constitute carrying on business in Canada 356
Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) USco not carrying on business in Canada by virtue of extensive marketing assistance (without client contact) work provided by Canadian affiliate 228

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 17. ("Supplier Reliance on Purchaser Certificates")

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Section 6.1

Administrative Policy

8 March 2018 CBA Commodity Tax Roundtable. Q. 17

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Words and Phrases
emergency

Section 6.3

See Also

ACN 154 520 199 Pty Ltd (in liquidation) v Commissioner of Taxation, [2020] FCAFC 190

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Words and Phrases
refining
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Precious Metal market criteria for gold to be in investment form 312

Section 7

Administrative Policy

"GST/HST In Electronic Commerce", CCRA Discussion Paper, November 2001.

Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 143 - Subsection 143(1) 0

23 October 2000 Interpretation 11640-1

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  GST/HST Memorandum 4.5.1 “Exports - Determining Residence Status” January 1998

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6 May 1998 HQ Letter

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Paragraph 7(d)

Administrative Policy

GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998

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Paragraph 7(f)

Administrative Policy

28 February 2019 CBA Roundtable, Q.8

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(g) registered non-resident marketer using services of a Canadian subcontractor was thereby making supplies in Canada 140

Section 10

See Also

Canada v. Dawn’s Place Ltd., [2006] GSTC 137, 2006 FCA 349

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Tax Topics - Treaties - Income Tax Conventions - Article 12 119

Administrative Policy

B-090 "GST/HST and Electronic Commerce" July 2002

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GST/HST Memorandum 4.5.3 “Exports – Services and Intellectual Property” June 1998

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29 October 1997 Ruling HQR0000558

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Articles

James Swanson, David Ross, "Taxing Intangibles - GST and the Supply of Digital Images", GST & Commodity Tax, Vol. XVII, No. 4, May 2003, p. 25.

Section 10.1

Administrative Policy

8 April 2016 Ruling 158060

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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 33. ("Application of S. 10.1, Sch. VI, P. V – Service Related to Intangible Personal Property")

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2 November 2012 Ruling Case No. 140160

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14 February 2012 Ruling Case No. 99181 [non-exclusive information use rights]

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4 February 2012 Ruling Case No. 99181 [information licence]

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GST/HST Info Sheet GI-034 "Exports of Intangible Personal Property" April 2007

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B-090 "GST/HST and Electronic Commerce" July 2002

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Section 12

Cases

Escape Trailer Industries Inc. v. Canada (Attorney General), 2020 FCA 54

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Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Financial Administration Act - Section 23 - Subsection 23(2) CRA had not unreasonably referenced the specific requirements of the zero-rating provision 249

See Also

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280

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Tax Topics - Excise Tax Act - Section 168 - Subsection 168(9) meaning of deposit adopted 55

Administrative Policy

Paragraph 12(a)

Cases

Montecristo Jewellers Inc. v. Canada, 2020 FCA 12

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) “delivery” for ETA purposes had its meaning under the Sale of Goods Act 353

Montecristo Jewellers Inc. v. The Queen, 2019 TCC 31, aff'd 2020 FCA 12

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Tax Topics - Excise Tax Act - Section 142 - Subsection 142(1) - Paragraph 142(1)(a) delivery in Canada as full voluntary transfer of possession there 328

Section 14

Section 15.1

Administrative Policy

May 2016 Alberta CPA Roundtable, GST Q.1

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Section 15.2

Administrative Policy

5 February 2013 Ruling Case No. 141852

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GST Memorandum (New Series) 3.7 (Draft), February 2012 para. 1040105: General Discussion. 2 August 2001 TI RITS 32561

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Section 18

Section 20

Paragraph 20(c)

Administrative Policy

3 April 2019 GST/HST Ruling 188947 - Tax status of supplies made by a municipality

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 20 - Paragraph 20(c) - Subparagraph 20(1)(c)(ii) fees for Municipality reviewing liquor licence application, including any public consultation charges, were exempt 86
Tax Topics - Excise Tax Act - Section 146 additional building inspection charges of municipality were taxable 88

Subparagraph 20(1)(c)(ii)

Administrative Policy

3 April 2019 GST/HST Ruling 188947 - Tax status of supplies made by a municipality

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Section 20 - Paragraph 20(c) exemption for building permits does not extend to charges for extra inspections or reviews or overtime 241
Tax Topics - Excise Tax Act - Section 146 additional building inspection charges of municipality were taxable 88

Section 23

Administrative Policy

31 August 2004 Headquarter Letter - RITS 50657

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24 July 2003 Ruling Case No. 41660

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9 April 2001 T.I. 33818

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P-169R Meaning of in Respect of Real Property Situated in Canada and in Respect of Tangible Personal Property that is Situated in Canada at Time the Service is Performed, for Purposes of Schedule VI, Part V, Sections 7 and 23 to the Excise Tax Act

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15 June 2000 Headquarters Letter RITS 31364

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1 September 1999 Headquarters Letter RITS HQR0001873

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Memorandum (New Series) 4-5-3 "Export - Services and Intellectual Property" June 1998

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Part VII

Section 1

Subsection 1(1)

Administrative Policy

Continuous Journey

Cases

Sunshine Coach Ltd v. The Queen, 2019 TCC 72 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 2 Alberta bus tours were not part of continuous journey performed outside Canada 112
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 3 Alberta bus tours were not part of continuous journey entailing continuous flight 102

Administrative Policy

Freight transportation service

See Also

Andrews v. The Queen, 2017 TCC 23 (Informal Procedure)

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Words and Phrases
transporting
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 8 drving car not transporting it 119

Vuruna v. The Queen, 2010 TCC 365 (Informal Procedure)

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Stopover

Administrative Policy

Section 5

Section 2

Cases

Sunshine Coach Ltd v. The Queen, 2019 TCC 72 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 3 Alberta bus tours were not part of continuous journey entailing continuous flight 102
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 1 - Subsection 1(1) - Continuous Journey international flight tickets were not issued by agents for Canadian bus tour operator 76

Administrative Policy

Section 3

Cases

Sunshine Coach Ltd v. The Queen, 2019 TCC 72 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 2 Alberta bus tours were not part of continuous journey performed outside Canada 112
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part VII - Section 1 - Subsection 1(1) - Continuous Journey international flight tickets were not issued by agents for Canadian bus tour operator 76

Administrative Policy

Section 4

Section 8

See Also

Andrews v. The Queen, 2017 TCC 23 (Informal Procedure)

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Section 15

Administrative Policy

27 April 2018 Ruling 185888

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Words and Phrases
ambulance
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply medical escort services were single supply 215
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 6 medical escort services could be single supply of nursing services where nurse etc. involved 200
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5 medical escort services could be single supply of physician’s services where physician involved, but not including delegated paramedic services 199

Part IX

Section 1

Cases

National Bank Life Insurance v. Canada, 2006 FCA 161

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Specific v. General Provisions zero-rating re insurance was to be dealt with exclusively under provision re insurance 147

See Also

CIBC World Markets Inc. v. The Queen, 2018 TCC 103, rev'd 2019 FCA 147

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 150 - Subsection 150(1) s. 150 election precluded zero-rating of services rendered to parent's NR branches 159

Administrative Policy

17 December 2015 Interpretation 153009

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply required shareholder communications not a supply 169
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f) dividend a financial supply to recipient 81
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) share issuance a financial supply to shareholder 164

11 July 1997 Technical Interpretation HQR0000416

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Guide for Providers of Financial Services under "Zero-rated Financial Services"

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Articles

David Schlesinger, "De Minimis Financial Institutions", 1995 Commodity Tax Symposium Papers, C. 17: Danny Cisterna, "Hot Topics for Financial Institutions," 1999 Commodity Tax Symposium Papers, C. 7: suggests that "relates to" requires a direct connection.

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Section 2

Paragraph 2(d)

See Also

Northbridge Commercial Insurance Corporation v. The Queen, 2020 TCC 132

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Words and Phrases
risks ordinarily situated

Section 3

Administrative Policy

Guide for Providers of Financial Services

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