In finding that a refund of federal sales tax that predecessors of the taxpayer previously had paid in error did not qualify as a reimbursement for purposes of s. 12(1)(x)(iv), Létourneau J.A. noted that Westcoast Energy had found that “in all of the examples of the word reimbursement [provided to the court], there exists a flow of benefits between the respective parties.” He then stated (at p. 6063):
"In the case of a refund of sums paid by error, there is, in my view, no flow of benefits between the respective parties: the money is simply returned to the payer. In addition, while the notion of reimbursement generally involves the intervention of a third party, that of refund implies the mere return of money between two parties."