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Supreme Court of Canada Agrees to Hear Case Involving Eligibility for Exclusion of Income Earned by Foreign Subsidiary Bank

|Approved Changes|Canada
Canada

On 29 October 2020, the Supreme Court of Canada issued a release to announce that it has granted the application for leave to appeal from the judgment of the Federal Court of Appeal, Number A-321-18, 2002020 FCA 79, dated 23 April 2020 in the case of Her Majesty the Queen v. Loblaw Financial Holdings Inc. (F.C.) (Civil) (By Leave) (39220).

During the taxable years at issue, the taxpayer was a Canadian company that was a parent company of a Barbados-based subsidiary. The subsidiary was a ba…

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