After finding that, under an agreement between the appellant (CIBC) and Aeroplan, the supply made by Aeroplan to CIBC was essentially labelled as...
|Locations of other summaries||Wordcount|
|Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply||agreement between bank and Aeroplan labelled the bank as receiving promotional services rather than purchasing Aeroplan Miles (being, mooted gift certificates)||477|
|Tax Topics - Excise Tax Act - Section 181.2||Aeroplan Miles were considered, by the sole Justice addressing the issue, to be gift certificates since no significant conditions to their redemption||348|
|Tax Topics - Income Tax Act - Section 171 - Subsection 171(1)||Tax Court not bound by an admission contrary to the interpretation of an agreement reviewed by it||174|
|Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 27 - Subsection 27(1.3)||fresh argument could not be made by taxpayer at the Court of Appeal level||190|