CRA continues to consider that form largely governs the sale/lease distinction

Although ITTN, No. 21 has been cancelled, last month CRA quoted approvingly a statement therein that "in the absence of sham, it is our view that a lease is a lease and a sale is a sale."

Neal Armstrong.  Summary of ITTN, No. 21: cancelled, but confirmed in 2014-0516921E5 F, under s. 13(21) – depreciable property.