A corporation resident in the United States ("Marco") obtained a licence of stadium facilities from the taxpayers and contracted with them for the provision of related services (e.g., ticket sales and the sale of food, beverages and souvenirs) in connection with the production of a figure skating show in Canada by Marco. Lamarre T.C.J. referred to the finding in Taylor v. MNR, [1988] 2 CTC 2227, at 2234 (TCC) that "the term 'services' refers not to the final product or end result of a transaction, but rather to the process by which this is achieved" and found (at p.