89 C.R. - Q.8

"A transaction that takes the form of a lease will ordinarily be treated as a lease for the purposes of the Act, on the presumption that the agreement is what it purports to be and that the legal rights under the agreement are those of a lessor and lessee."

"A lease is a contract by which a person who owns property grants to another the right to possess, use and enjoy the property for a specific period of time for periodic payments of the stipulated price, referred to as rent, with the obligation to return the property at the term of the lease ... . Transactions which are structured as management agreements or licences and under the terms of which a lessee/lessor relationship does not exist would not generally be considered as leases for income tax purposes."