Asset Management Service

Table of Contents

Asset Management Service
See Also(1)
Administrative Policy(2)
Articles(1)

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...

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Words and Phrases
asset management
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) - 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

Administrative Policy

GST/HST Notice 344, Application of the GST/HST to Mutual Fund Trailing Commissions, 26 May 2026

Extension of GST/HST to trailer commissions

  • The Notice confirmed that “[a]s a result of … industry developments” CRA “will enforce the...

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22 December 2025 GST/HST Interpretation 246664 - Tax status of trailing commissions

CRA responded to a submission that GST/HST did not apply to dealer trailing commissions earned by a dealer (the “New Dealer”) who is not the...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) MFT trailer fees are taxable even if paid to originating dealer 373

Articles

EY, "CRA intends to postpone new administrative position on GST/HST treatment of trailing commissions", EY Tax Alert – Canada, Issue No. 30, 14 May 2026

In 22 December 2025 GST/HST Interpretation 246664, CRA rejected a submission that GST/HST did not apply to dealer trailing commissions earned by a...

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