Words and Phrases - "underwriting"
State Farm Mutual Auto Insurance Co. v. The Queen, [2003] GSTC 35
After finding that the U.S. head office of the appellant (an auto insurer) did not render or supply services to the Canadian regional office, Bowman A.C.J. went on to find that if such services were rendered, they were financial services. He noted that the respondent's argument "would essentially restrict financial services, in the context of the insurance business, to the issuance of an insurance policy to an insured" and that the concept of underwriting was much broader than this. Further , if any administrative or management services were attributed to the categories of insurance performed by the head office for the Canadian regional office, they were incidental to the financial services, so that s. 138 applied.
Words and Phrases
underwritingLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Excise Tax Act - Section 138 | 84 | |
Tax Topics - Excise Tax Act - Section 220 | charges to Canadian branch of an allocated portion of head office expenses were not for services rendered | 72 |