Ainsworth Lumber Co. Ltd. v. The Queen, 2001 DTC 496 (TCC) -- summary under Transitional Provisions and Policies

A project to utilize a timber resource to produce oriented strand board in Grande Prairie was found to be "substantially advanced" before February 22, 1994 given that before that date the taxpayer "had done an immense amount of work ... to put itself in a highly informed and highly equipped position to prepare and submit [after that date] what proved to be a winning bid" (p. 510). Bell T.C.J. noted (at p. 510) that the taxpayer "had clearly made much more than 'just nominal or insignificant progress' in the pursuit of its project" and that "the word 'substantially' does not have to be quantified by a percentage."