Canadian Imperial Bank of Commerce v. The Queen,

JurisdictionFederal Jurisdiction (Canada)
Neutral Citation2021 TCC 71
Citation2021 TCC 71
CourtTax Court (Canada)
Date02 November 2021
    • This document is available in original version only for vLex customers

      View this document and try vLex for 7 days
    • TRY VLEX
3 practice notes
  • Independent Order of Foresters v. The King, 2023 TCC 123
    • Canada
    • Tax Court (Canada)
    • August 17, 2023
    ...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......
  • Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
    • Canada
    • Court of Appeal (Canada)
    • May 4, 2023
    ...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......
  • CIBC v. The King, 2023 FCA 91.
    • Canada
    • Mondaq Canada
    • September 18, 2023
    ...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
  • Independent Order of Foresters v. The King, 2023 TCC 123
    • Canada
    • Tax Court (Canada)
    • August 17, 2023
    ...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......
  • Canadian Imperial Bank of Commerce v. Canada, 2023 FCA 91
    • Canada
    • Court of Appeal (Canada)
    • May 4, 2023
    ...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
  • CIBC v. The King, 2023 FCA 91.
    • Canada
    • Mondaq Canada
    • September 18, 2023
    ...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......

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT