In finding that payments made by the taxpayer to its U.S. parent for the use by it of equipment in its Canadian business represented "rent, royalty or a similar payment" under s. 106(1)(d) of the pre-1972 Act, Thurlow J. stated (at p. 1105):
"... In its ordinary usage, as opposed to its technical legal meaning, the word 'rent', besides referring to returns of that nature from real property, is broad enough to include a payment for the hire of personal property ... . The subsection ... include[s] a fixed amount paid as rental for the use of personal property for a certain time."