Section 181.2

Table of Contents

Cases

Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 96

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply agreement between bank and Aeroplan labelled the bank as receiving promotional services rather than purchasing Aeroplan Miles (being, mooted gift certificates) 477
Tax Topics - Excise Tax Act - Section 309 - Subsection 309(1) Tax Court not bound by an admission contrary to the evidence before it 173
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) Tax Court not bound by an admission contrary to the interpretation of an agreement reviewed by it 174
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 27 - Subsection 27(1.3) fresh argument could not be made by taxpayer at the Court of Appeal level 190

See Also

Canadian Imperial Bank of Commerce v. The Queen, 2019 TCC 79, aff'd 2021 FCA 96

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
gift certificate
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply Aeroplan points program occurred as single supply 264
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Service Aeroplan Miles were supplied by Aeroplan to CIBC as a taxable service 376
Tax Topics - Excise Tax Act - Section 138 supply of Aeroplan Miles was ancillary to promotional services 370

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) taxable supply of frequent flyer points 146
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 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

Administrative Policy

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 35.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 April 2013 Ruling Case No. 141283 [vouchers applied to purchase goods up to dollar limit were coupons]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

P-202 "Gift Certificates" April 2012

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

24 October 2011 Ruling Case No. 138563

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

27 September 2011, Ruling Case No. 131157

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 August 2011 Headquarters Letter 127020

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

19 July 2011 Headquarters Letter 127619

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2000 Headquarters Letter RITS/No. HQR0001726 (8120)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.