The taxpayer partly financed the acquisition of buses by means of its bank purchasing conditional sales contracts from a manufacturer. Marceau J.A. found that the contractual relationship between the bank and the taxpayer was determined by the initial contract between them when a line of credit was established. Accordingly, both ss.181.2(3)(c) and (d) applied: the money owed by the taxpayer to the bank under the line of credit was both a loan and also a debt secured by the transfer of rights set out in the conditional instalment sales contracts.
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