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Royal Bank of Canada v. The King, 2024 TCC 125 -- summary under Paragraph 1(a)

Full Title
Royal Bank of Canada v. The King, 2024 TCC 125
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 - Paragraph 1(a)
foreign interchange fees generated by Canadian credit card issuer related to the granting of credit rather than the making of a loan by it, and were not excluded under s. 1(a)(ii)

When cardholders of credit cards issued by the appellant (RBC) used their cards for purchases from a foreign merchant, RBC would earn an...

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Words and Phrases
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granting of credit
lending of money

Cassan v. The Queen, 2017 TCC 174 -- summary under Paragraph 143.2(7)(a)

Full Title
Cassan v. The Queen, 2017 TCC 174
Summary Under
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a)
loans were not bona fide in that not handled with commerciality

In December 2009, individual taxpayers participated in a tax shelter that involved making both a leveraged investment (the "LP Program") and...

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Words and Phrases
bona fide
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