The appellant hospital was created by amalgamation and enjoyed a general exemption from provincial taxation under its incorporating statute.
The province subsequently amended the Retail Sales Tax Act to provide that no person is exempt from retail sales tax by reason of an exemption in another Act unless that other Act expressly mentions the Retail Sales Tax Act.
The Court of Appeal held that this amendment removed the appellant's general exemption from retail sales tax, as the incorporating statute did not expressly mention the Retail Sales Tax Act in a way that reflected an intention to preserve the general exemption.
