Words and Phrases - "issue estoppel"

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Canadian Imperial Bank of Commerce v. The Queen, 2022 TCC 26, aff'd 2023 FCA 195

issue 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...

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Words and Phrases
issue estoppel
Locations of other summaries Wordcount
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