The appellant municipality abolished its business occupancy tax and restructured its property tax system.
The respondent federal Crown corporations, which previously made payments in lieu of property taxes but not business taxes, deducted an amount equivalent to the abolished business tax from their payments in lieu of taxes.
The Supreme Court of Canada held that the respondents' decisions were unreasonable because they based their calculations on a fictitious tax system rather than the one actually in place.
The Court also found that the port authority's silos were not 'reservoirs' exempt from the calculation.
