Words and Phrases - "relates to"
Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 - Paragraph 1(a) - Subparagraph 1(a)(ii)CIBC’s interchange fees from a non-resident credit-card processor were not zero-rated as relating to the loans effectively made to its Cdn. cardholders
In 2001 (before the three annual fiscal periods in issue) the appellant (CIBC) outsourced part of its Visa-card transaction processing and payment...
Locations of other summaries | Wordcount | |
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Tax Topics - Excise Tax Act - Section 280 - Subsection 280(1) - Paragraph 280(1)(a) | due diligence defence established based on reasonable filing position | 55 |
Potash Corporation of Saskatchewan Inc. v. The Queen, 2022 TCC 75, aff'd 2024 FCA 35
sales of potash “related to” potash production
The taxpayer, which produced and sold potash from mines in Saskatchewan, was subject to both a profit tax and to the making of “base payments”...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | deductibility of Saskatchewan potash tax “base payments” denied given that sales they were applied to were a proxy for income | 357 |