Financial Service

See Also

FP Newspapers Inc. v. The Queen, 2013 TCC 44 (Informal Procedure)

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Tax Topics - Excise Tax Act - Section 141 - Subsection 141(3) 177
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(2) s. 272.1 did not apply to limited partner 260

Global Cash Access (Canada) Inc. v. The Queen, 2012 TCC 173, rev'd in part 2013 FCA 269

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Aim Funds Management Inc. v. Aim Trimark Corporate Class Inc., [2009] O.J. No. 4798, [2009] GSTC 170, 64 DLR (4th) 261, 2009 CanLII 29491 (Ont. Sup. Ct. J.)

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Tax Topics - General Concepts - Rectification & Rescission 157

The Canadian Medical Protective Association v. The Queen, 2008 TCC 33, [2008] GSTC 88, aff'd supra

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General Motors of Canada Limited v. The Queen, [2008] GSTC 41, 2008 TCC 117, aff'd [2009] GSTC 64, 2009 FCA 114

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient employer was recipient of portfolio advisory fees for employees' pension fund 78
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) recipient acquires the services 209

Canada Trustco Mortgage Company v. The Queen, 2004 TCC 792

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply sale of mortgages on fully-serviced basis 139
Tax Topics - Excise Tax Act - Section 138 sale of mortgages on fully-serviced basis with deferred purchase price labelling 243

State Farm Mutual Auto Insurance Co. v. The Queen, [2003] GSTC 35

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Words and Phrases
underwriting
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 138 84
Tax Topics - Excise Tax Act - Section 220 charges to Canadian branch of an allocated portion of head office expenses were not for services rendered 72

Ingle Manor Farms Inc. v. The Queen, docket 2001-862-GST-I (TCC) (Informal Procedure)

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Drug Trading Company Ltd. v. The Queen, [2001] GSTC 48 (TCC) (Informal Procedure)

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Skylink Voyages Inc. v. The Queen, [1999] GSTC 119 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply cancellation charges were consideration for a supply 188
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk "slight" risk in accepting credit card slips rendered a person at risk 336
Tax Topics - General Concepts - Agency 205

C.I. Mutual Funds Inc. v. Canada, [1997] GSTC 84 (TCC), aff'd [1999] GSTC 12 (FCA)

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On-Guard Self-Storage Ltd. v. The Queen, [1996] GSTC 9 (TCC)

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Locator of Missing Heirs Inc. v. The Queen, [1995] GSTC 63 (TCC)

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Commissioner of Inland Revenue v. Databank Systems Ltd., [1990] BTC 5108 (PC)

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Customs and Excise Commissioners v. Diners Club Ltd., [1989] BTC 5084, [1989] 2 All E.R. 385 (C.A.)

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Administrative Policy

19 November 2020 GST/HST Ruling 209409 - – Tax Status of Financial Planning Services

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5 June 2012 Interpretation Case No. 127795

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5 June 2012 Interpretation Case No. 81635

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17 May 2012 Interpretation File 97556

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9 January 2012 Ruling 9 January 2012 Ruling Case Number 112274 -

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31 October 2011 Interpretation Case No. 132880

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5 January 2012 Ruling Case No. 98811 [broker charge for securing health plan employer]

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10 November 2011 Case No. 125071

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6 September 2011 Ruling 6 September 2011 Ruling Case No. 77006

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29 July 2011 Headquarters Letter 95868

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Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) card loyalty program credits 112

29 July 2011 Headquarters Letter Case No. 82567

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19 July 2011 Headquarters Letter 127619

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Tax Topics - Excise Tax Act - Section 181.2 272

19 July 2011 Headquarters Letter Case No. 111922

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Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) insurance policy administration 77

19 July 2011 Headquarters Letter Case No. 125864

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15 June 2011 Headquarters Letter Case No. 108590

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GST/HST Notice 250, "Proposed Changes to the Definition of Financial Service", June 2010.

26 July 2007 Ruling 26 July 2007 Ruling 63048 -

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December 2006 GST/HST Info Sheet GI-006 "ABM Services"

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5 April 2004 Ruling Case No. 50019

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17 December 2003 Ruling Case No. 45758

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17 December 2003 Ruling Case No. 40640

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2 December 2003 Memorandum Case No. 41678

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19 November 2002 Interpretation RITS 42355

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P-239 "Meaning of the Term 'Arranging For' as Provided in the Definition of 'Financial Service'" 30 January 2002. 31 March 2000 HQ Letter 25522

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GST/HST Memorandum 17.1.1 Products and Services of Investment Dealers October 2001

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (b) inactivity fee to brokerage client is exempt 36

Draft Policy Statement on the Meaning of the Term 'Arranging for', 18 January 2000, No. 11595-2

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21 December 1999 Headquarters Letter 8177/HQR0001783

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21 December 1999 Ruling File 11595-2 No. HQR0001783/8177

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27 October 1999 HQ Letter HQR0001895

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25 August 1998 Ruling RITS HQR0001269 [trailer fees]

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3 September 1997 Ruling HQR0000579

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P-210 "Performance Bond Claims" dated 7 February 1997. P-192 "Supply of Precious Metals" P-119 "Trailer Commission Servicing Fees"

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GST M 300-4-7 "Financial Services" GST M 700-2 "Definition of 'Financial Instrument'" B-032 "Registered Pension Plans and Registered Retirement Savings Plans"

B-033 "GST Treatment of Products and Services of a Deposit-Taking Financial Institution"

Articles

Paragraph (a)

Cases

Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) VISA provided a GST/HST-exempt financial service to CIBC 421
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

See Also

Wiltonpark Ltd & Ors v Revenue & Customs Commissioners, [2016] EWCA Civ 1294

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HMRC v National Exhibition Centre Ltd., [2016] BVC 19, Case C-130/15 (ECJ (8th Chamber))

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply additional “booking” charges by a service provider to those paying by credit card were not consideration for a separate supply 409

Paragraph (b)

Administrative Policy

GST/HST Memorandum 17.1.1 Products and Services of Investment Dealers October 2001

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Paragraph (c)

See Also

ING Intermediate Holdings Ltd v HMRC, [2017] EWCA Civ 2111

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply services provided in deposit-taking business were more than peripheral so that supplies were made 290
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) interest paid by bank to depositors was reduced by implied fees earned as consideration going to the bank 143
Tax Topics - General Concepts - Substance court only goes behind the contract if the contract does not reflect the true agreement 187

Administrative Policy

Paragraph (d)

Administrative Policy

3 September 2019 GST/HST Interpretation 173195 - […][Mutual Fund Units]

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Words and Phrases
transfer of ownership
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) unit trust redemption fee would generally be exempted from GST/HST if it was payable by the redeeming unitholder to the trust rather than the fund manager 202
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (q) para. (q) inapplicable to any subscription or redemption fees payable by redeeming unitholders to fund manager given that they were borne by them rather than Funds 237

24 January 2018 Ruling 156434

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Debt Security conditional sales contracts and credit agreements were debt securities 198

19 May 2017 Interpretation 178323

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Tax Topics - Excise Tax Act - Section 240 - Subsection 240(1) no backdating of registration of pure holding LP 80

21 December 2016 Ruling 157873

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply assignment fee was part of consideration for assignment 69

17 December 2015 Interpretation 153009

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 potential zero-rating re share issuances and dividends 86
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

18 October 2013, TMX Notice to Participating Organizations and Members, 2013-036

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28 January 2008 GST/HST Ruling 84428

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8 February 2005 Interpretation Case No. 52141

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Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) stock options valued based on in-the-money value 112
Tax Topics - General Concepts - Fair Market Value - Options in-the-money stock option valuation 41

Paragraph (f)

See Also

Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONCA 727

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Words and Phrases
fee interest
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) daily discount fee had the 3 attributes of interest 381

Stock ‘94 Szolgáltató Zrt. v Regional Customs and Finance Directorate-General for Southern Transdanubia of the National Tax and Customs Office, Hungary, Case C-208/15, [2016] BVC 45 (European Court of Justice (5th Chamber))

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply interest on loan to fund taxable supply was part of taxable consideration 143

Administrative Policy

27 February 2020 CBA Roundtable, Q.16

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17 September 2018 Ruling 182403

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(1) partnership draws exempted under (f) of financial service 64

8 March 2018 CBA Commodity Taxes Roundtable, Q.7

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Money CRA reviewing whether crypto-currencies are "money" 390

17 December 2015 Interpretation 153009

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 potential zero-rating re share issuances and dividends 86
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 (d) share issuance a financial supply to shareholder 164

21 January 2010 GST/HST Ruling 111598

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Words and Phrases
commodity

Paragraph (f.1)

Cases

Great-West Life Assurance Company v. Canada, 2016 FCA 316

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) predominant character of insurance claim processing was administrative 250
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

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) electronic drug plan adjudication and processing was "quintessentially administrative in nature" 279
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

Administrative Policy

10 January 2018 Interpretation 139614

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Tax Topics - Excise Tax Act - Section 175 - Subsection 175(1) s. 175 not available to employer who through a PHSP reimburses personal health care costs of employee 262

Paragraph (g)

Cases

Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration "consideration" under law of contract 123
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply three elements integrally connected 240
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) "consideration" under law of contract 123
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) predominant element not described in (r.4) or (r.5) 183

See Also

Vega International Car Transport and Logistic — Trading GmbH v. Dyrektor Izby Skarbowej w Warszawie, ECLI:EU:C:2019:412 (European Court of Justice, 8th Chamber)

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Words and Phrases
granting of credit credit

Administrative Policy

29 January 2015 Ruling 93176 [commitment fee paid to loan assignor exempt]

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Paragraph (i)

See Also

Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of payment platform 162
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) Visa arranged for payments between cardholder bank, merchant’s bank and merchant 268
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Asset Management Service services provided by Visa to bank were not an asset management service 239
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) no (r.3) service as Visa did not assist in credit authorization 191
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) services provided by Visa that were listed in (r.4) were not the predominant elements 199
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) limited use of Visa logo did not engage (r.5) 146
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) Visa service to CIBC was an administrative service 186
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(3) - Paragraph 4(3)(c) activities of Visa were too passive to be of a "broker" 235
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk not a "person at risk" if risk is very remote 419

Paragraph (j.1)

Administrative Policy

20 December 2018 Ruling 189221

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Paragraph (l)

Cases

SLFI Group v. Canada, 2019 FCA 217

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (q) dominant element in supply by funder of broker commissions was a financing service rather than a management service 514
Tax Topics - Excise Tax Act - Section 261 - Subsection 261(2) - Paragraph 262(2)(b) denial includes where the CRA assessment of the tax was of another person 428
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 tax characterization not affected by securities law characterization 87

Canada v. Costco Wholesale Canada Ltd., 2012 FCA 160

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Words and Phrases
consideration
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) payments by credit card company to store were not merely discounts to its fees 184

Animal Rescue Missions of Canada Inc. v. Canada (Customs and Revenue Agency), [2009] G.S.T.C. 65, 2008 FCA 115

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Words and Phrases
arrange for

See Also

Zomaron Inc. v. The Queen, 2020 TCC 35

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) a service of inducing merchants to use credit card processing services was an exempt financial service 553

Applewood Holdings Inc. v. The Queen, 2018 TCC 231

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) promotional and administrative services of car dealer were ancillary to the customers' insurance purchases 370

Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10

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Words and Phrases
arranging for
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of payment platform 162
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (i) Visa provided services to CIBC that related to an agreement for which credit card vouchers were issued 216
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Asset Management Service services provided by Visa to bank were not an asset management service 239
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) no (r.3) service as Visa did not assist in credit authorization 191
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) services provided by Visa that were listed in (r.4) were not the predominant elements 199
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) limited use of Visa logo did not engage (r.5) 146
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) Visa service to CIBC was an administrative service 186
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(3) - Paragraph 4(3)(c) activities of Visa were too passive to be of a "broker" 235
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk not a "person at risk" if risk is very remote 419

Barr v. The Queen, 2018 TCC 86

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) broker services in “promoting” the sale of a company to prospective purchasers would have come within (r.4) 216

Mac's Convenience Stores Inc. v. The Queen, 2012 TCC 393

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Tax Topics - Excise Tax Act - Section 185 - Subsection 185(1) impulse purchases generated by ABM machine customers represented sufficient link 154

Global Cash Access (Canada) Inc. v. The Queen, 2012 TCC 173, rev'd in part 2013 FCA 269

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service 377
Tax Topics - Excise Tax Act - Section 138 taxable element insufficiently minor 262

President's Choice Bank v. The Queen, 2009 TCC 170

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Royal Bank of Canada v. The Queen, [2007] GSTC 122, 2007 TCC 281

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply taxable supply of frequent flyer points 207
Tax Topics - Excise Tax Act - Section 181 - Subsection 181(1) - Coupon frequent flyer points could be coupons 114
Tax Topics - Excise Tax Act - Section 181.2 frequent flyer points not gift certificates 121
Tax Topics - Excise Tax Act - Section 278 - Subsection 278(2) s. 278(2) precluded direct collection on assessment of recipient until supplier released from remittance obligation under CCAA 330
Tax Topics - Excise Tax Act - Section 296 - Subsection 296(1) - Paragraph 296(1)(b) no double taxation in s. 296(1)(b) assessment of purchaser because supplier had been released from its remittance obligation under CCAA plan 262

Les Promotions D.N.D. Inc. v. The Queen, 2006 TCC 63

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Administrative Policy

Excise and GST/HST News - No. 109, June 28, 2021

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Tax Topics - Excise Tax Act - Section 211.12 - Subsection 211.12(2) CRA will use “discretion” in its first 12 months of administering the new e-commerce rules 91
Tax Topics - Excise Tax Act - Regulations - Public Service Body Rebate (GST/HST) Regulations - Section 3 - Subsection 3(1) - Paragraph 3(1)(a) CEWS not included in total revenue or in government assistance 236

24 January 2020 GST/HST Ruling 194625 - Services Provided to an Introducing Broker by a Carrying Broker

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Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk indemnity from introducing broker suggested that carrying broker was not a person at risk 322

3 September 2019 GST/HST Interpretation 173195 - […][Mutual Fund Units]

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) unit trust redemption fee could be consideration for the “transfer of ownership” of units to the trust 452
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (q) para. (q) inapplicable to any subscription or redemption fees payable by redeeming unitholders to fund manager given that they were borne by them rather than Funds 237

2 May 2019 GST/HST Ruling 150998 - Fees charged in relation to project loans

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) non-refundable fee paid by borrower to lender’s agent to perform due diligence and take the financing project through to closing were taxable preparatory services 237
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) predominant nature of fees paid to loan agent was for loan management 159

Excise and GST/HST News - No. 102 July 2017

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Excise and GST/HST News - No. 106 June 2019

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) car dealer's selling and processing credit insurance is exempted 202

23 March 2017 CBA Commodity Taxes Roundtable, Q.12

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16 December 2016 Interpretation 169841

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Excise and GST/HST News, No. 100, November 2016

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4 February 2014 Interpretation 106288

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20 July 2012 Ruling 20 July 2012 Ruling Case No.137528 [taxable rebate fees from credit card issuer received by retailer] -

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29 June 2012 Interpretation Case No. 104941

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17 May 2012 Ruling 62492

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4 June 2012 Interpretation Case No. 131194

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15 March 2012 Ruling 15 March 2012 Ruling Case No. 132880-2 -

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14 July 2011 Headquarters Letter Case No. 132388

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17 May 2011 Headquarters Letter Case No. 129875

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27 May 2011 Headquarters Letter Case No. 129882

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19 May 2011 Interpretation Case No. 131970

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GST/HST Technical Information Bulletin B-105 February 2011 "Changes to the Definition of Financial Service"

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Words and Phrases
arranging for

Paragraph (q)

Cases

SLFI Group v. Canada, 2019 FCA 217

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) dominant element in MFT commission funding arrangement was the payment, or the arranging of payment, of the funding 187
Tax Topics - Excise Tax Act - Section 261 - Subsection 261(2) - Paragraph 262(2)(b) denial includes where the CRA assessment of the tax was of another person 428
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 tax characterization not affected by securities law characterization 87

See Also

SLFI Group - Invesco Canada Ltd. v. The Queen, 2017 TCC 78, rev'd in part 2019 FCA 217

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Tax Topics - Excise Tax Act - Section 217 - Imported Taxable Supply - Paragraph (a) non-resident vehicle provided taxable imported supply in funding MFT brokerage commissions 281
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply dominant element of service provided by financing SPV was financing 180

The Colleges of Applied Arts and Technology Pension Plan v. The Queen, 2003 GTC 899-62, 2003 TCC 618

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Words and Phrases
principal activity

Administrative Policy

3 September 2019 GST/HST Interpretation 173195 - […][Mutual Fund Units]

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) unit trust redemption fee could be consideration for the “transfer of ownership” of units to the trust 452
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) unit trust redemption fee would generally be exempted from GST/HST if it was payable by the redeeming unitholder to the trust rather than the fund manager 202

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 14

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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 9 ("Financial Services and Exclusion in Paragraph (q)")

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Paragraph (r.3)

See Also

Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of payment platform 162
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) Visa arranged for payments between cardholder bank, merchant’s bank and merchant 268
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (i) Visa provided services to CIBC that related to an agreement for which credit card vouchers were issued 216
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Asset Management Service services provided by Visa to bank were not an asset management service 239
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) services provided by Visa that were listed in (r.4) were not the predominant elements 199
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) limited use of Visa logo did not engage (r.5) 146
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) Visa service to CIBC was an administrative service 186
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(3) - Paragraph 4(3)(c) activities of Visa were too passive to be of a "broker" 235
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk not a "person at risk" if risk is very remote 419

Administrative Policy

2 May 2019 GST/HST Ruling 150998 - Fees charged in relation to project loans

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) non-refundable fee paid by borrower to lender’s agent to perform due diligence and take the financing project through to closing were taxable preparatory services 237
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) fee paid for taking a financing from signing through to closing is taxable 180

Paragraph (r.4)

Cases

Global Cash Access (Canada) Inc. v. Canada, 2013 FCA 269

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration "consideration" under law of contract 123
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (g) commercial efficacy of arrangement involving kiosk and support services turned on the advance of money 428
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply three elements integrally connected 240
Tax Topics - Excise Tax Act - Section 153 - Subsection 153(1) "consideration" under law of contract 123

See Also

Zomaron Inc. v. The Queen, 2020 TCC 35

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Words and Phrases
arranging for
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) finding and signing-up merchants to use the services of a credit card payment processor was an arranging-for service 288

Applewood Holdings Inc. v. The Queen, 2018 TCC 231

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) a car dealer who promoted and processed credit insurance to its customers was “arranging for” insurance 244

Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of payment platform 162
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) Visa arranged for payments between cardholder bank, merchant’s bank and merchant 268
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (i) Visa provided services to CIBC that related to an agreement for which credit card vouchers were issued 216
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Asset Management Service services provided by Visa to bank were not an asset management service 239
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) no (r.3) service as Visa did not assist in credit authorization 191
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) limited use of Visa logo did not engage (r.5) 146
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) Visa service to CIBC was an administrative service 186
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(3) - Paragraph 4(3)(c) activities of Visa were too passive to be of a "broker" 235
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk not a "person at risk" if risk is very remote 419

Barr v. The Queen, 2018 TCC 86

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) broker fees paid to locate purchasers of a private company were HST-taxable 430

Rojas v. The Queen, 2016 TCC 177 (Informal Procedure)

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Great-West Life Assurance Company v. The Queen, 2015 TCC 225

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Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) electronic drug plan adjudication and processing was "quintessentially administrative in nature" 279
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.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

Administrative Policy

2 May 2019 GST/HST Ruling 150998 - Fees charged in relation to project loans

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) predominant nature of fees paid to loan agent was for loan management 159
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) fee paid for taking a financing from signing through to closing is taxable 180

6 May 2019 GST/HST Interpretation 194986 - – […][Services of a Managing General Agent]

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Excise and GST/HST News - No. 106 June 2019

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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) CRA accepts Applewood (re para. (l) exemption for car dealers who sell, explain and process credit insurance provided to their customers) 235

Paragraph (r.5)

See Also

Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply single supply of payment platform 162
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) Visa arranged for payments between cardholder bank, merchant’s bank and merchant 268
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (i) Visa provided services to CIBC that related to an agreement for which credit card vouchers were issued 216
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Asset Management Service services provided by Visa to bank were not an asset management service 239
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.3) no (r.3) service as Visa did not assist in credit authorization 191
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) services provided by Visa that were listed in (r.4) were not the predominant elements 199
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) Visa service to CIBC was an administrative service 186
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(3) - Paragraph 4(3)(c) activities of Visa were too passive to be of a "broker" 235
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(1) - Person at Risk not a "person at risk" if risk is very remote 419

Great-West Life Assurance Company v. The Queen, 2015 TCC 225

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) electronic drug plan adjudication and processing was "quintessentially administrative in nature" 279
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 - General Concepts - Payment & Receipt constructive receipt by relieving obligation to pay pharmacist 236

Paragraph (t)

Cases

Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) - Paragraph 4(2)(b) VISA provided a GST/HST-exempt financial service to CIBC 421
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (a) VISA supplied a payment service to CIBC 109

Administrative Policy

Excise and GST/HST News, No. 100, November 2016

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