The Toronto-Dominion Bank v. The King, 2024 TCC 50 -- summary under Subsection 306.1(1)

By services, 6 May, 2024

TD, whose appeal was focused on the question of whether payments which it made to Aeroplan for purchase Aeroplan Miles were not subject to HST on the basis of being consideration for gift certificates, was not precluded from arguing that payments which it made to another bank (CIBC) in respect of Aeroplan Miles also enjoyed the same treatment (notwithstanding that such payments were not referenced in its objection) given that CRA had regarded this issue as being included in TD’s objection.

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CRA was aware that the ancillary issue that was not explicitly raised was included in the objection
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d7 import status
Drupal 7 entity type
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Drupal 7 entity ID
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