Before noting at para. 54, that it was conceded by the Crown that the appellant's principal activity was not the investing of funds (its principal activity being defending lawsuits against doctors), Bowman, C.J. found (at para. 54) that the discretionary investment management services provided to the taxpayer were not "management ... services":
The juxtaposition in paragraph (q) of the words "management" and "administrative" implies the type of managerial function associated with running a business. Management and administration fees are paid generally to individuals or corporations to handle the variety of matters necessary for the functioning of a business. I should not have thought that "managing" a portfolio of investments carried that type of connotation.