93 C.M.TC - Q. 8

RC does not consider the Viceroy Rubber case to have precedential value because of its unusual facts and will maintain its policy in IT-361R2, para. 9, that financial leases are not obligations that can meet the requirements of s. 212(1)(b)(vii).

Notwithstanding the Viceroy Rubber case, RC will not provide rulings that a lease results in the disposition of property. There would seldom, if ever, be a bona fide business reason for entering into a transaction that is portrayed as a lease when a disposition of property was intended.