Bow River Pipe Lines Ltd. v. R., 97 DTC 5385, [1997] 3 C.T.C. 397 (FCA) -- summary under Transitional Provisions and Policies

After indicating (at p. 5398) that "the Tax Court judge did not err in concluding that the words 'agreement in writing' did not require that the agreement create 'contractual rights and obligations'", Desjardins J.A. found that the taxpayer was not grandfathered with respect to an amendment to s. 98(5) because the agreement in question did not bind it to acquire a partnership interest.