Canadian Imperial Bank of Commerce v. The Queen,
Jurisdiction | Federal Jurisdiction (Canada) |
Neutral Citation | 2021 TCC 71 |
Citation | 2021 TCC 71 |
Court | Tax Court (Canada) |
Date | 02 November 2021 |
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3 practice notes
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Independent Order of Foresters v. The King, 2023 TCC 123
...Ruth Sullivan, Statutory Interpretation, 3rd ed. (Toronto: Irwin Law, 2016) at page 326; Canadian Imperial Bank of Commerce v. The Queen, 2021 TCC 71, paragraph 53, Aff’d, 2023 FCA 91. [39] Income Tax Act, R.S.C. 1952, c. 148, as amended by An Act to amend the Income Tax Act, S.C. 19......
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Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
...the disposition of Class B Shares of CIBC Delaware Holdings Inc. to be nil. [3] The Tax Court answered this question in the affirmative (2021 TCC 71, per Owen [4] For the reasons that follow, I would dismiss this appeal. I. Agreed Facts [5] The parties agreed on the facts submitted to the T......
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CIBC v. The King, 2023 FCA 91.
...Footnotes 1. Canadian Imperial Bank of Commerce v. The King, 2023 FCA 91. [CIBC FCA] 2. Canadian Imperial Bank of Commerce v. The Queen, 2021 TCC 71. [CIBC 3. Subsection 39(2) was amended in 2013 by 2013, c. 34, s. 59, applicable to gains made and losses sustained in taxation years that beg......
2 cases
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Independent Order of Foresters v. The King, 2023 TCC 123
...Ruth Sullivan, Statutory Interpretation, 3rd ed. (Toronto: Irwin Law, 2016) at page 326; Canadian Imperial Bank of Commerce v. The Queen, 2021 TCC 71, paragraph 53, Aff’d, 2023 FCA 91. [39] Income Tax Act, R.S.C. 1952, c. 148, as amended by An Act to amend the Income Tax Act, S.C. 19......
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Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
...the disposition of Class B Shares of CIBC Delaware Holdings Inc. to be nil. [3] The Tax Court answered this question in the affirmative (2021 TCC 71, per Owen [4] For the reasons that follow, I would dismiss this appeal. I. Agreed Facts [5] The parties agreed on the facts submitted to the T......
1 firm's commentaries
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CIBC v. The King, 2023 FCA 91.
...Footnotes 1. Canadian Imperial Bank of Commerce v. The King, 2023 FCA 91. [CIBC FCA] 2. Canadian Imperial Bank of Commerce v. The Queen, 2021 TCC 71. [CIBC 3. Subsection 39(2) was amended in 2013 by 2013, c. 34, s. 59, applicable to gains made and losses sustained in taxation years that beg......