The taxpayer managed its Ontario properties through four Ontario employees, whereas its Alberta properties were managed by three corporations pursuant to management agreements with it. In finding that the fees paid in Alberta were not deemed to be salary by Regulation 302(7) under the Corporations Tax Act (Ontario), Feldman J.A. noted that in Alberta the modus operandi of the taxpayer was to contract out management of the properties rather than to have employees of the taxpayer manage those properties and that the scheme of the provisions was not to equate all labour whether performed by employees or contractors.