What is the interpretation of s. 2.1(1) of the Income Tax Code on a vessel?
British Columbia, Canada
The following excerpt is from Metlakatla Ferry Service Ltd. v. B.C. (Govt.), 1987 CanLII 2748 (BC CA):
The alternative interpretation, espoused by the respondent, is that while the tax is on the lease price, the property to which it relates is the vessel itself. The respondent argues that just as a tax on a “purchase price” under s. 2(1) is “in respect of the thing purchased (Danes v. R. in Right of B.C.), so a tax on a “lease price” under s. 2.1(1) is “in respect of the thing leased, that is, the vessel.
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