Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Court of Appeal (Canada) |
| Citation | 2021 FCA 10 |
| Date | 22 January 2021 |
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16 practice notes
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Gee v. The Queen,
...SCC 14, [2019] 1 SCR 729, at para 33; it must be plain to see and it must affect the result: Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10, 456 D.L.R, (4th) 722, at para. 55. It means the Tax Court Judge’s findings of fact must be treated with a high degree of deference: ......
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632738 Alberta Ltd. v. Canada, 2021 FCA 43
...is palpable when it is plainly seen, and overriding when it affects the result” (Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10 at para. 55). [17] In the analysis below, all but one of the issues raise questions of mixed fact and law for which the palpable and overriding e......
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Canadian Imperial Bank of Commerce v. The Queen, 2022 TCC 83
...Cash Access (Canada) v R, 2013 FCA 269 at paras 25‑26, 37‑38 [Global Cash]; Canadian Imperial Bank of Commerce v. The Queen, 2021 FCA 10 [CIBC (Visa)] at para 32. [20] February 11, 2022 Transcript, p 473, line 24 to p 478, lines 2‑23. [21] Ibid, p 478, lines 4‑17......
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President's Choice Bank v. The Queen, 2022 TCC 84
...(Aeroplan)]. [142] CIBC (Aeroplan), supra note 141 at paras 33 and 34. [143] CIBC (Aeroplan), supra note 141 at paras 57‑58. [144] 2021 FCA 10 [CIBC (Visa)]. [145] As those terms are defined in section 4 of the Regulations. [146] CIBC (Visa), supra note 144 at para 4. [147] Written S......
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8 cases
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Gee v. The Queen,
...SCC 14, [2019] 1 SCR 729, at para 33; it must be plain to see and it must affect the result: Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10, 456 D.L.R, (4th) 722, at para. 55. It means the Tax Court Judge’s findings of fact must be treated with a high degree of deference: ......
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632738 Alberta Ltd. v. Canada, 2021 FCA 43
...is palpable when it is plainly seen, and overriding when it affects the result” (Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10 at para. 55). [17] In the analysis below, all but one of the issues raise questions of mixed fact and law for which the palpable and overriding e......
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Canadian Imperial Bank of Commerce v. The Queen, 2022 TCC 83
...Cash Access (Canada) v R, 2013 FCA 269 at paras 25‑26, 37‑38 [Global Cash]; Canadian Imperial Bank of Commerce v. The Queen, 2021 FCA 10 [CIBC (Visa)] at para 32. [20] February 11, 2022 Transcript, p 473, line 24 to p 478, lines 2‑23. [21] Ibid, p 478, lines 4‑17......
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President's Choice Bank v. The Queen, 2022 TCC 84
...(Aeroplan)]. [142] CIBC (Aeroplan), supra note 141 at paras 33 and 34. [143] CIBC (Aeroplan), supra note 141 at paras 57‑58. [144] 2021 FCA 10 [CIBC (Visa)]. [145] As those terms are defined in section 4 of the Regulations. [146] CIBC (Visa), supra note 144 at para 4. [147] Written S......
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8 firm's commentaries
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Federal Court On VISA Supplying Financial Services: Tax Guidance
...GST/HST Federal Court of Appeal decision will benefit financial institutions In Canadian Imperial Bank of Commerce v Canada, 2021 FCA 10, CIBC (the appellant) which issues Visa credit cards, was seeking GST/HST rebates on fees charged by Visa for the supply the bank received as a participan......
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Federal Court Of Appeal Decides That Visa Services To CIBC Are Exempt Financial Services, Not Administrative Services For GST/HST Purposes
...22, 2021 the Federal Court of Appeal (FCA) released its reasons in Canadian Imperial Bank of Commerce v. The Queen, 2021 FCA 10, overturning the decision of the Tax Court of Canada (the "TCC") and finding that services provided by Visa to CIBC were exempt from the GST/HST as financial servi......
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Budget 2023: Raising The Stakes For Aggressive Tax Planning
...sales tax measure aimed to nullify the decision of the Federal Court of Appeal in Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10, wherein the Court held that credit card and payment processing services supplied by Visa to the card issuing bank (and by extension to other participa......
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Highlights Of Canada's 2023 Federal Budget
...to exempt the supply of a "financial service" from GST/HST. The Federal Court of Appeal in Canadian Imperial Bank of Commerce v. Canada, 2021 FCA 10, held that credit-card companies (such as Visa and MasterCard) provide an exempt supply of a financial service to credit card issuers, such th......
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