Words and Phrases - "issue estoppel"
Canadian Imperial Bank of Commerce v. The Queen, 2022 TCC 26, aff'd 2023 FCA 195
Summary Under
Tax Topics - General Concepts - Res Judicataissue estoppel will rarely apply respecting transactions carried out in different taxation years
After President's Choice Bank (the “2009 Decision”) determined that services supplied by a subsidiary of Loblaw (“PC Bank”) to another...
Words and Phrases
issue estoppelLocations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) | the continued correctness of PC Bank “now hangs by a thread” because of the addition of (r.4) | 239 |