Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 182
| Jurisdiction | Federal Jurisdiction (Canada) |
| Citation | 2018 TCC 182 |
| Court | Tax Court (Canada) |
| Date | 07 September 2018 |
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7 practice notes
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Canada v. Loblaw Financial Holdings Inc.,
...C.T.C. 1 , 2020 D.T.C. 5040 , [2020] F.C.J. No. 511 (QL), 2020 CarswellNat 1300 (WL Can.), setting aside a decision of Miller J., 2018 TCC 182, [2019] 2 C.T.C. 2001 , 2018 D.T.C. 1128 , [2018] T.C.J. No. 136 (QL), 2018 CarswellNat 5099 (WL Can.). Appeal dismissed. &#x......
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Loblaw Financial Holdings Inc. c. Canada,
...Ltd. v. Minister of National Revenue, [1944] 3 D.L.R. 545 , [1944] A.C. 126 (P.C.).APPEAL from a decision of the Tax Court of Canada (2018 TCC 182) upholding the Minister of National Revenue’s determination that the income from the appel-lant’s Barbados subsidiary was forei......
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Supreme Court Of Canada Unanimously Rules That Loblaw Financial Holdings Inc. Was Entitled To Benefit From The "financial Institution" Exception In The "FAPI" Rules
...3. Referring to the decisions of the Tax Court of Canada and the Federal Court of Appeal. See Loblaw Financial Holdings Inc. v The Queen, 2018 TCC 182; and Canada v Loblaw Financial Holdings Inc., 2020 FCA 79, 4. Loblaw Financial, at para 239 of the Tax Court decision. 5. Canada v Loblaw Fi......
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Federal Court Of Appeal Overturns Tax Court Decision And Clarifies The Arm's Length Requirement In The Foreign Bank Exclusion To The FAPI Rules
...whether it carries on its business in a particular place. Footnotes 1. 2020 FCA 79, reversing Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 182. 2. Ibid., at para 51. Originally published 28 May 2020 The content of this article is intended to provide a general guide to the subject m......
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3 cases
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Canada v. Loblaw Financial Holdings Inc.,
...C.T.C. 1 , 2020 D.T.C. 5040 , [2020] F.C.J. No. 511 (QL), 2020 CarswellNat 1300 (WL Can.), setting aside a decision of Miller J., 2018 TCC 182, [2019] 2 C.T.C. 2001 , 2018 D.T.C. 1128 , [2018] T.C.J. No. 136 (QL), 2018 CarswellNat 5099 (WL Can.). Appeal dismissed. &#x......
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Loblaw Financial Holdings Inc. c. Canada,
...Ltd. v. Minister of National Revenue, [1944] 3 D.L.R. 545 , [1944] A.C. 126 (P.C.).APPEAL from a decision of the Tax Court of Canada (2018 TCC 182) upholding the Minister of National Revenue’s determination that the income from the appel-lant’s Barbados subsidiary was forei......
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Loblaw Financial Holdings Inc. v. Canada, 2020 FCA 79
...an exclusion provided to foreign banks. Loblaw Financial appealed from the reassessments to the Tax Court. [3] In a decision reported as 2018 TCC 182, the Tax Court agreed with the Minister that the foreign bank exclusion did not apply. The basis for the Court’s conclusion was that Glenhuro......
4 firm's commentaries
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Supreme Court Of Canada Unanimously Rules That Loblaw Financial Holdings Inc. Was Entitled To Benefit From The "financial Institution" Exception In The "FAPI" Rules
...3. Referring to the decisions of the Tax Court of Canada and the Federal Court of Appeal. See Loblaw Financial Holdings Inc. v The Queen, 2018 TCC 182; and Canada v Loblaw Financial Holdings Inc., 2020 FCA 79, 4. Loblaw Financial, at para 239 of the Tax Court decision. 5. Canada v Loblaw Fi......
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Federal Court Of Appeal Overturns Tax Court Decision And Clarifies The Arm's Length Requirement In The Foreign Bank Exclusion To The FAPI Rules
...whether it carries on its business in a particular place. Footnotes 1. 2020 FCA 79, reversing Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 182. 2. Ibid., at para 51. Originally published 28 May 2020 The content of this article is intended to provide a general guide to the subject m......
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Supreme Court Of Canada Unanimously Rules That Loblaw Financial Holdings Inc. Was Entitled To Benefit From The "financial Institution" Exception In The "FAPI" Rules
...3. Referring to the decisions of the Tax Court of Canada and the Federal Court of Appeal. See Loblaw Financial Holdings Inc. v The Queen, 2018 TCC 182; and Canada v Loblaw Financial Holdings Inc., 2020 FCA 79, 4. Loblaw Financial, at para 239 of the Tax Court decision. 5. Canada v Loblaw Fi......
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What's New In Tax Controversy And Litigation?
...(Investments) S.A., 2007 FCA 236; Prévost Car Inc. v. Canada, 2009 FCA 57; Velcro Canada Inc. v. The Queen, 2012 TCC 57, respectively. 8 2018 TCC 182. 9 2019 TCC 10 2018 TCC 195. 11 2019 FC 377. The content of this article is intended to provide a general guide to the subject matter. Specia......