Cases
CIBC World Markets Inc. v. Canada, 2019 FCA 147
The Crown argued that the language in s. 132(3) was inadequate to deem a non-resident permanent establishment of an affiliate of the appellant...
| 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 |