Royal Bank of Canada v. The Queen, [2007] GSTC 122, 2007 TCC 281 -- summary under Section 181.2

A Canadian airline ("CAIL") entered into an agreement with the appellant ("RBC") to promote use of RBC's credit card and to honour frequent flyer points to be awarded by it to RBC at the rate of one Point for every dollar of qualifying credit spending. After rejecting (at para. 47) the Minister's submission "that the Points cannot be gift certificates for want of a stated or face value," Hershfield J stated (at para. 51) "that if the certificate entitles the holder to an identifiable supply, it can still be a gift certificate," and found (at para. 55) that here "the Points cannot be considered to be a gift certificate…as there is no fixed correlation between the Points issued and their use."