Subsection 18(2) only limited deductions otherwise available and did not establish that property taxes that the taxpayer was unable to deduct under section 9 due to the application of the matching principle, were deductible.
Dubé J. found that a tax is a levy that is "(1) enforceable by law; (2) imposed under the authority of a legislature; (3) imposed by a public body and (4) for a public purpose". (p. 5357)