CIBC World Markets Inc. v. Canada, 2019 FCA 147
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|Locations of other summaries||Wordcount|
|Tax Topics - Excise Tax Act - Section 132 - Subsection 132(3)||a non-resident PE had deemed separate person status sufficient to insulate it from an ETA s. 150 election||305|
|Tax Topics - Excise Tax Act - Section 132 - Subsection 132(4)||expansive deemed person language required because 2 PEs involved||372|
|Tax Topics - Excise Tax Act - Section 150 - Subsection 150(2)||s. 150(2) amendment was required because of the risk of taxpayers arguing otherwise||469|
|Tax Topics - Statutory Interpretation - Ordinary Meaning||ambiguity can arise on consideration of how the provision interacts with another||172|
|Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply||no supplies between PEs of the same person in the absence of s. 132(4)||70|