Alberta (Treasury Branches) v. M.N.R.; Toronto-Dominion Bank v. M.N.R., 96 DTC 6245, [1996] 1 SCR 963, [1996] 1 CTC 395 -- summary under Subsection 224(1.2)

The Minister had priority under s. 224(1.2) of the Act and s. 317 of the Excise Tax Act over lending institutions that had taken general assignment of book debts as collateral security for their loans. Unlike the minority, who found that the lenders were not "secured creditors" because they did not have a security interest in the property of "another person", Cory J. found that because the lenders would have no further interest in the assignments once the secured loans were paid off, the assignments could not be considered absolute assignments and, instead, conformed with the definition of "security interest".