The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205 (FCA) -- summary under Interpretation/Definition Provisions

After being referred to the statement in Verrette [1978] 2 S.C.R. 838 at 844 that "in definition provisions, the word 'includes' is generally used extensively in contradistinction to the restrictive word 'means'," Heald J.A. accepted (at p. 6160) a submission of the Crown that the word "including" in s. 212(1)(d) was used in its extensory sense for the purpose of enlarging the meaning of the preceding words, so that payments described after the word "including" were subject to the charge of the section whether or not they could be said to be ejusdem generis with "rent, royalty or a similar payment".