CI Burland Properties Limited v MNR, 68 DTC 5220 (SCC) -- summary under Paragraph 212(1)(d)

Municipal taxes which, under the terms of the real property lease between the non-resident taxpayer and a resident tenant, the tenant agreed to pay were found to be payments similar to rent made for the use in Canada of property and, therefore, were subject to withholding tax under s. 106(1)(d) of the pre-1972 Act, which applied to a "rent, royalty or a similar payment, including, but not so as to restrict the generality of the foregoing, any such payment ... for the use in Canada of property".