Saskatchewan ( Government Insurance ) v. Canada
A-513-97
Strayer J.A.
9/12/99
4 pp.
Appeal from Trial Division decision ((1997] 131 F.T.R. 290) involving interpretation of Excise Tax Act, s. 44.19(1)-Licence plates in question purchased by Crown in right of Saskatchewan-Purchased by Saskatchewan Government Insurance (SGI), statutory agent of Crown, by expenditure of funds belonging to Crown-Whether SGI made "use" of licence plates as contemplated by Act, s. 44.19(1)(b)-There may be more than one purpose for purchase of taxable goods-Rebate excluded if any of those purposes involves use described in s. 44.19(1)(a), (b), (c)-SGI using licence plates when issuing licence plates to motorists for purpose of administering automobile registration system for province, as well as for operating compulsory automobile insurance scheme-By ordinary meaning of word "use", SGI thus using plates in carrying out duties with lawful control of plates for these purposes-Appeal dismissed-Excise Tax Act, R.S.C. 1970, c. E13, s. 44.19 (as am. by S.C. 1986, c. 9, s. 34).