The taxpayer, along with other credit unions, was required to deposit with the Ontario Share and Deposit Insurance Corporation ("OSDIC") amounts equal to 1% of its capital.
A refund to it of these amounts was included in its income under s. 137.1(10) notwithstanding that the amounts deposited had not become OSDIC's property. Lamarre T.C.J. found (at p. 802) that the deposited sums qualified as an "assessment", i.e., "a sum specifically levied ... by a mutual company ... to pay losses or losses and administrative expenses incurred". Furthermore, the word "allocation" did not imply that OSDIC was required to own the amounts deposited, but instead merely denoted the possibility that a member institution might not be repaid the entire amount initially paid.