Words and Phrases - "arranging for"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
55
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Zomaron Inc. v. The Queen, 2020 TCC 35

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l)
finding and signing-up merchants to use the services of a credit card payment processor was an arranging-for service

CRA viewed the taxpayer (Zomaron) as essentially a marketing arm of two “Processors” (e.g., “Elavon”) that accessed the credit card issuer...

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Words and Phrases
arranging for
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) a service of inducing merchants to use credit card processing services was an exempt financial service 553

Zomaron Inc. v. The Queen, 2020 TCC 35

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4)
a service of inducing merchants to use credit card processing services was an exempt financial service

The appellant (“Zomaron”) negotiated with and obtained from prospective merchants a commitment to use the card payment processing services of...

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Words and Phrases
arranging for
Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l) finding and signing-up merchants to use the services of a credit card payment processor was an arranging-for service 288

Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, rev'd 2021 FCA 10

Summary Under
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

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
arranging for
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 (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) - Asset Management Service services provided by Visa to bank were not an asset management service 239
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

Canada v. Canadian Medical Protective Association, 2009 FCA 115, [2009] G.S.T.C. 65

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l)
discretionary investment management

Discretionary investment management services provided by investment managers to a not-for-profit corporation that provided professional liability...

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Words and Phrases
arranging for

GST/HST Technical Information Bulletin B-105 February 2011 "Changes to the Definition of Financial Service"

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (l)

Meaning of "arranging for"

In its preliminary discussion of para. (l), CRA stated:

The term “arranging for” is generally intended to include...

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Words and Phrases
arranging for