Words and Phrases - "bank"

a
88
b
44
c
78
d
52
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 182, rev'd on s. 95(1) - investment business - (a) (arm's length conduct) grounds 2020 FCA 79, in turn aff'd 2021 SCC 51

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Bank
CFA qualified as a foreign bank since it was licensed under Barbados law as an international bank

The Minster assessed the taxpayer on the basis that its Barbados subsidiary (GBL) had realized $473 million of foreign accrual property income (FAPI) between 2001 and 2010. In finding that the business of GBL was that of a foreign bank described in s. 2(a) of the Bank Act whose activities were regulated under Barbados law, C Miller J noted (at para. 154) that the International Financial Services Act (Barbados) (“IFSA”) and predecessor legislation “contemplate banking as the receipt of foreign funds for financial transactions involving foreign money, debt instruments, securities or assets conducted with foreign counterparties,” noted that the Barbados central bank “viewed GBL as a bank” (para. 163) and that GBL was licensed as an international bank under the IFSA (para. 204).

Words and Phrases
bank