- Parties: The appellant was the President's Choice Bank. The respondent was His Majesty the King.

- Subject Matter: As part of a loyalty program, the appellant bank reimbursed Loblaws with a redemption payment for a discount received by customers when they redeemed at Loblaws stores credit card points issued by the bank. The issue in this appeal was whether the bank could claim notional input tax credits (NITCs) for the redemption payment. The Minister of National Revenue conceded that the redemption payment fulfilled all except one of the criteria for NITCs, specifically that the payment be made in the course of a commercial activity. The Tax Court ruled in the Minister’s favour.

- Ruling: The appeal court ruled in the appellant’s favour, allowed the appeal from the reassessment notices dated Mar. 26, 2014 (for the annual reporting period commencing Dec. 31, 2008 and ending Dec. 30, 2009) and June 23, 2015 (for the annual reporting periods ending Dec. 30, 2010; Dec. 30, 2011; and Dec. 30, 2012), set aside the Tax Court judgment, and referred the reassessments back to the Minister for reassessment on the basis that the bank was entitled to claim the NITCs relating to the redemption payment that it made.

- Date: The hearing was set on Mar. 6, 2024. The court released its decision on Aug. 21, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: The appeal court awarded costs in this court and the court below.