The Appellant (a car manufacturer) was the administrator of various defined benefit pension plans for its unionized employees. It was the recipient of portfolio advisory services as it rather than the plans was contractually liable to pay the advisors' fees, and the Crown did not dispute that it also "acquired" those services if s. 167.1 did not apply to deem those services to instead have been acquired by the plans (which it did not).
These services also satisfied the requirement in s. 169(1) that they have been acquired by it in the course of its commercial activities. As noted by the Campbell, J below, its employee compensation program was a necessary adjunct to its making taxable sales, and it was contractually obligated to maintain the plans as part of that program.