Casa Blanca Homes Ltd. v. The Queen, 2013 TCC 338 (Informal Procedure) -- summary under Debt Security

The appellant bought and resold the right and obligation to acquire lots from a land developer. Hogan J found that the "non-refundable" deposits collected thereon were each a "debt security" under s. 123(1), given that the collection of a sum under a contract as a "deposit" implies an obligation to return the deposit if the collector does not perform the contract - in this case, if the land developer were unable to complete the lots on time (para. 24). In the alternative, the purchaser's assignment of the deposits to third parties was not a supply at all, because money is neither property not a service (para. 22, adopting Barnett 2011).