Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2018 TCC 109 |
| Date | 22 June 2018 |
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9 practice notes
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Vocan Health Assessors Inc. v. The Queen,
...in Global Cash Access (Canada) Inc. v The Queen, 2013 FCA 269 , [2013] G.S.T.C. 141. [29] Canadian Imperial Bank of Commerce v The Queen, 2018 TCC 109, [2018] G.S.T.C. [30] CIBC, at para 67.This Court found that the supply CIBC received from Visa was not an exempt supply of a financial ser......
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Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10
...Minister of National Revenue issued assessments denying the rebate claims. CIBC’s appeal to the Tax Court of Canada was dismissed (2018 TCC 109, Rossiter C.J.). The Tax Court concluded that the supply CIBC received from Visa was an administrative, not a financial, service, and that V......
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Zomaron Inc. v. The Queen, 2020 TCC 35
...for” captured the use of an intermediary in the provision of financial services. Recently, in Canadian Imperial Bank of Commerce v R, 2018 TCC 109, [2018] G.S.T.C. 57 (“CIBC”), Chief Justice Rossiter relied on and applied the approach and principle in Promotions D.N.D. [81] Generally, princ......
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Tax Court Rules That VISA's Services Are Subject To GST/HST
...namely VISA's payment platform offering to financial institutions. In Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2018 TCC 109, Chief Justice Rossiter held that the supply of services made by VISA to CIBC fell outside the financial service definition in the Excise Tax Act (C......
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4 cases
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Vocan Health Assessors Inc. v. The Queen,
...in Global Cash Access (Canada) Inc. v The Queen, 2013 FCA 269 , [2013] G.S.T.C. 141. [29] Canadian Imperial Bank of Commerce v The Queen, 2018 TCC 109, [2018] G.S.T.C. [30] CIBC, at para 67.This Court found that the supply CIBC received from Visa was not an exempt supply of a financial ser......
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Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10
...Minister of National Revenue issued assessments denying the rebate claims. CIBC’s appeal to the Tax Court of Canada was dismissed (2018 TCC 109, Rossiter C.J.). The Tax Court concluded that the supply CIBC received from Visa was an administrative, not a financial, service, and that V......
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Zomaron Inc. v. The Queen, 2020 TCC 35
...for” captured the use of an intermediary in the provision of financial services. Recently, in Canadian Imperial Bank of Commerce v R, 2018 TCC 109, [2018] G.S.T.C. 57 (“CIBC”), Chief Justice Rossiter relied on and applied the approach and principle in Promotions D.N.D. [81] Generally, princ......
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Applewood Holdings Inc. v. The Queen, 2018 TCC 231
...renders the profitable product an element of a service being provided per se. [30] In Canadian Imperial Bank of Commerce v. The Queen, 2018 TCC 109, Chief Justice Rossiter opined at paragraph 67: In considering the Appellant’s and Respondent’s arguments, they both seem to be in agreement th......
5 firm's commentaries
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Tax Court Rules That VISA's Services Are Subject To GST/HST
...namely VISA's payment platform offering to financial institutions. In Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2018 TCC 109, Chief Justice Rossiter held that the supply of services made by VISA to CIBC fell outside the financial service definition in the Excise Tax Act (C......
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Visa Does Not Supply GST/HST Exempt 'Financial Services', Tax Court Rules In A Landmark Decision
...is properly collected on services as confirmed by the Tax Court. Footnotes Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2018 TCC 109. Great-West Life Assurance Co. v. The Queen, 2015 TCC Costco Wholesale Canada Ltd. v. The Queen, 2009 TCC 134. In the Regulations, a "person at......
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Décision De La Cour De L'imp't Infirmée - Visa Effectue Des Fournitures Exonérées De ' Services Financiers ' En TPS/TVH
...the GST/HST will not need to be filed anymore by such entities. Footnotes > 1 Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2018 TCC 109. 2 Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2021 FCA 3 In the Regulations, a "person at risk" is defined as, in respect o......
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2023 Federal Budget: Sales And Excise Tax Measures
...and Services Tax/Harmonized Sales Tax joint venture election. Footnotes 1. Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2018 TCC 109. 2. Canadian Imperial Bank of Commerce v Her Majesty the Queen, 2021 FCA 3. Supra note 1, para. 75. The content of this article is intended to ......
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