After finding that interchange fees generated by CIBC were not zero-rated, Sommerfeldt J found that CIBC had established a due diligence defence to reverse the penalties imposed under former ss. 280(1)(a) and 280(2)(a) given inter alia that “CIBC’s filing position was not unreasonable” (para. 138) and had been prepared by qualified tax-group employees.
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due diligence defence established based on reasonable filing position
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
917297
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
917298
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Workflow state