Canada v. Bank of Montreal, 2020 FCA 82
| Jurisdiction | Federal Jurisdiction (Canada) |
| Citation | 2020 FCA 82 |
| Court | Court of Appeal (Canada) |
| Date | 04 May 2020 |
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6 practice notes
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Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
...113 at 119. 146 ITA , above note 1, s 245(1), “tax beneit.” 147 Copthorne , above note 136 at para 35. In Canada v Bank of Montreal , 2020 FCA 82, the Court of Appeal found that there was no tax beneit because, subsequent to the interpretation of the provisions applicable at the time, the t......
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Canadian Imperial Bank of Commerce v. The Queen,
...to instead have the new rule apply in respect of taxation years of all foreign affiliates of the taxpayer that end after June 2011. [4] 2020 FCA 82 [5] The Appellant’s argument correctly recognizes that the deeming rule in subsection 39(2) applies to a net amount determined at the en......
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Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
...of National Revenue denied CIBC’s claim for an allowable capital loss. II. Decision of this Court in Canada v. Bank of Montreal, 2020 FCA 82 [9] The decision of this Court in BMO played a dominant role in the decision of the Tax Court and in the arguments of CIBC in this appeal. The ......
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AgraCity Ltd. v. The Queen, Case Study
...2020 DTC 5059 (F.C.A.); Loblaw Financial Holdings Inc. v. The Queen, 2020 DTC 5040 (F.C.A.), and Bank of Montréal v. The Queen, 2020 FCA 82 The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circum......
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3 cases
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Canadian Imperial Bank of Commerce v. The Queen,
...to instead have the new rule apply in respect of taxation years of all foreign affiliates of the taxpayer that end after June 2011. [4] 2020 FCA 82 [5] The Appellant’s argument correctly recognizes that the deeming rule in subsection 39(2) applies to a net amount determined at the en......
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Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
...of National Revenue denied CIBC’s claim for an allowable capital loss. II. Decision of this Court in Canada v. Bank of Montreal, 2020 FCA 82 [9] The decision of this Court in BMO played a dominant role in the decision of the Tax Court and in the arguments of CIBC in this appeal. The ......
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Bank of Montreal v. The Queen, 2021 TCC 3
...LLP Toronto, Ontario For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada [1] 2018 TCC 187. [2] 2020 FCA 82. [3] As the parties have agreed to these points, I have not considered them. [4] Schedule II, Tariff B of the Tax Court of Canada Rules (Gene......
2 firm's commentaries
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AgraCity Ltd. v. The Queen, Case Study
...2020 DTC 5059 (F.C.A.); Loblaw Financial Holdings Inc. v. The Queen, 2020 DTC 5040 (F.C.A.), and Bank of Montréal v. The Queen, 2020 FCA 82 The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circum......
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CIBC v. The King, 2023 FCA 91.
...are traded in U.S. dollars. " https://www.ourcommons.ca/DocumentViewer/en/41-2/FINA/report-12/page-54 8. The Queen v. Bank of Montreal, 2020 FCA 82. 9. See Elie S. Roth and Ryan Wolfe, "CIBC v Canada: A Matter of Precedence", International Tax Highlights, Volume 2,, Number 3, August 2023. T......
1 books & journal articles
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Fifty Years of Taxation at the Federal Court of Appeal and the Federal Court
...113 at 119. 146 ITA , above note 1, s 245(1), “tax beneit.” 147 Copthorne , above note 136 at para 35. In Canada v Bank of Montreal , 2020 FCA 82, the Court of Appeal found that there was no tax beneit because, subsequent to the interpretation of the provisions applicable at the time, the t......