Hewlett Packard (Canada) Ltd. v. Canada, 2004 DTC 6498, 2004 FCA 240 -- summary under Provincial Law

After finding that the taxpayer had not transferred the ownership of old fleets of cars before the end of its current taxation year for purposes of the Civil Code of Quebec as well as under the common law provinces, Noël J.A. went on to note (at p. 6506) that even if the application of the Civil Code gave rise to a different result, "this Court has held that, for the sake of uniformity, the common law approach should prevail even in Quebec."