Words and Phrases - "lending of money"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Royal Bank of Canada v. The King, 2024 TCC 125

Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 - Paragraph 1(a)
foreign interchange fees generated by Canadian credit card issuer related to the granting of credit rather than the making of a loan by it, and were not excluded under s. 1(a)(ii)

When cardholders of credit cards issued by the appellant (RBC) used their cards for purchases from a foreign merchant, RBC would earn an...

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Words and Phrases
relate to granting of credit lending of money
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11) issue should be stated "reasonably" 131
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(21) pre-approval of method for allocating inputs between foreign and domestic supplies did not stop CRA from assessing to deny zero-rating of the foreign supplies 202
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(31) - Paragraph 141.02(31)(f) s. 141.02(31)(f) is merely confirmatory of normal taxpayer onus 98
Tax Topics - Excise Tax Act - Section 141.02 - Subsection 141.02(1) - Direct Input expenses of redeeming credit card loyalty points were inextricably linked to the issuer’s extension of credit, and only remotely linked to its earning zero-rated interchange fees 368
Tax Topics - Excise Tax Act - Section 169 - Subsection 169(1) expenses of redeeming credit card loyalty points were an integral component of the issuer’s extension of credit, and not sufficiently connected to earning interchange fees 181
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient merchant acquirer was the recipient of credit card interchange services even though it was a conduit to the merchant 91
Tax Topics - Statutory Interpretation - Exclusionary provisions exclusionary provisions should be narrowly construed 267
Tax Topics - Excise Tax Act - Section 301 - Subsection 301(1.2) - Paragraph 301(1.2)(a) taxpayer not precluded from raising an argument that the Minister was bound by an ITC method that it had described in detail in its pleadings 175