Tribunals Ontario
Tribunaux décisionnels Ontario
Assessment Review Board
Commission de révision de l’évaluation foncière
ISSUE DATE: September 14, 2023
Assessed Person(s): General Motors of Canada Company, Cami Automotive Inc.
Appellant(s): General Motors of Canada Company
Respondent(s): Municipal Property Assessment Corporation Region 23
Respondent(s): Town of Ingersoll, Township of South-West Oxford
Property Location(s): See Schedule A
Municipality(ies): Town of Ingersoll, Township of South-West Oxford
Roll Number(s): 3211-011-020-41400 and 3218-030-065-31100
Appeal Number(s): See Schedule A
Taxation Year(s): 2009 to 2023
Hearing Event No.: 734564
Legislative Authority: Sections 32, 33, and 40 of the Assessment Act, R.S.O. 1990, c. A.31
APPEARANCES:
| Parties | Counsel/Representative* |
|---|---|
| General Motors of Canada Company | Jack A. Walker Stephen L. Longo Jamie G. Walker Lynne Ashton |
| Municipal Property Assessment Corporation | David G. Cowling Mackenzie Campbell |
| Town of Ingersoll, Township of South-West Oxford | Guy Tudino* |
HEARD: April 20, 2023 in writing
ADJUDICATOR(S): Dirk VanderBent, Vice-Chair
DECISION
OVERVIEW
1This is the Decision of the Assessment Review Board (the “Board”) following its Interim Decision in General Motors of Canada Company v Municipal Property Assessment Corporation Region 23, 2023 CanLII 12249 (ON ARB) (the “Interim Decision”).
2General Motors of Canada Company (the “Appellant”) is the owner of the property located at 300 Ingersoll Street South (the “Subject Property”). It is a light vehicle assembly plant which has produced the CAMI vehicle model for all taxation years under appeal (“CAMI Plant”). Its location spans the municipal boundary between the Town of Ingersoll and the Township of Southwest Oxford (the “Municipalities”). The Appellant has filed appeals pursuant to s. 40 of the Assessment Act, S.O. 1990, c. A.31 (the “Act”) for the first taxation year in each of three Assessment Cycles being: 2009, 2013, and 2017. Pursuant to the deeming provisions under the Act, appeals have been deemed for the remaining taxation years in each Assessment Cycle.
3The Board conducted a hearing of the appeals and issued the Interim Decision on February 13, 2023. A Decision could not be issued because the Board found that it had not received the necessary evidence to decide two matters: the calculation of the current value of the Subject Property for each taxation year, and whether an equitable adjustment is required pursuant to s. 44(3)(b) of the Act.
4The parties have provided the current value of the Subject Property for each taxation year under appeal other than the deemed appeal for the 2023 taxation year.
5With respect to equitable adjustment, the parties agree that there should be an equitable adjustment to reduce the current value of the Subject Property for all taxation years under appeal. However, they are unable to agree on the quantum of that reduction. Accordingly, they have adduced additional evidence and written submissions in support of their positions. The Board has found that these written materials are sufficient to adjudicate the equitable adjustment issue, so the Board has conducted this final phase of the adjudication by written hearing.
6The purpose of this Decision is to confirm the current values of the Subject Properties and provide the Board’s analysis and findings regarding the quantum of equitable adjustment.
7The Board’s analysis and findings, as well as the defined names and terms, from the Interim Decision apply in this Decision.
RESULT
8The Board finds that the correct current values are as set out in the following table, provided by the parties:
| Taxation Year | Agreed Current Values |
|---|---|
| 2009 - 2012 | $77,591,470 |
| 2013 - 2016 | $99,285,244 |
| 2017 | $100,463,728 |
| 2018 - 2021 | $116,757,608 |
| 2022 | $123,817,543 |
9The Board also finds that an equitable adjustment is required for each of the taxation years under appeal. The quantum of the reductions are set out in the following table:
| Taxation Year | Equitable Reduction |
|---|---|
| 2009 - 2012 | $28,657,470 |
| 2013 - 2016 | $27,679,244 |
| 2017 | $23,989,728 |
| 2018 - 2021 | $27,976,608 |
| 2022 | $27,192,543 |
10As the parties did not specify the correct current value of the Subject Property for the deemed appeal for the 2023 taxation year, or classification apportionments for any of the taxation years, the parties are directed to provide confirmation of these values as set out in the Order below.
ISSUE FOR THE HEARING
11The sole issue is the quantum of the equitable adjustment to reduce the current value of the Subject Property for each of the 2009 to 2023 taxation years.
ANALYSIS
Introduction
Relevant Legislation
12Section 44(3)(b) of the Act states:
(3) For 2009 and subsequent taxation years, in determining the value at which any land shall be assessed, the Board shall,
(a) determine the current value of the land; and
(b) have reference to the value at which similar lands in the vicinity are assessed and adjust the assessment of the land to make it equitable with that of similar lands in the vicinity if such an adjustment would result in a reduction of the assessment of the land.
Points of Comparison
13For the reasons explained in the Interim Decision (paragraphs 201 to 268), when determining whether an equitable adjustment is required, some of the components of the Cost Approach calculations constitute relevant points of comparison and some do not. Relevant points of comparison include: the area of the replacement facility, more specifically in this case, the Efficiency Ratio used to calculate the area of the new replacement facility; construction costs rates; depreciation rate used to determine physical deterioration; and percentage rate used to calculate economic obsolescence. The components that do not constitute a relevant point of comparison include: effective age of the property (used to determine physical deterioration); excess operating costs; and land value.
14The parties agree that MPAC applied the same depreciation rate schedule for all three assessment cycles, and, with the exception of one minor variance, the same percentage adjustments for economic obsolescence. However, there is a major difference regarding construction cost rates.
Construction Cost Rates
15In the Interim Decision, the Board found that, for purposes of calculating the current value of the Subject Property using the Cost Approach, the Average Replacement Cost Per Square Foot is $132.56 for the January 1, 2016 valuation day. The current value of the Subject Property for the 2016 assessment cycle was then time adjusted to arrive at the current values for the 2008 and 2012 assessment cycles. Therefore, the Average Replacement Cost Per Square Foot for these two assessment cycles, are, in effect, based on values obtained by applying the time adjustment to the $132.56 value.
16However, as discussed below, this $132.56 rate, and the two time-adjusted rates are higher than the rates that were used when calculating the current value of the similar properties in each of the three assessment cycles.
17The Appellant has analysed the average per square foot construction cost rates applied by MPAC when calculating the current value assessment (“CVA”) of similar properties (the “Actual Average Cost Rates”). The results are set out in the following table provided by the Appellant, organized by each assessment cycle:
| RCN Rates per MPAC Assessment Details | 2008 CVA | 2012 CVA | 2016 CVA |
|---|---|---|---|
| Brampton | $60.12 | $68.63 | $104.26 |
| Windsor | $59.28 | $66.40 | $98.33 |
| Oakville | $55.70 | $75.88 | $91.25 |
| Oshawa | $58.88 | $65.74 | $100.06 |
| Alliston | $71.38 | $81.33 | $99.42 |
| Cambridge | $74.61 | $80.88 | $117.95 |
| Woodstock | $66.99 | $75.47 | $119.45 |
| Median^4 | $60.12 | $72.05 | $100.06 |
| Difference from CAMI | -$58.62 | -$54.44 | -$32.50 |
| -49% | -43% | -25% |
^4 The median cost rate calculation excludes Cambridge for 2012 and Cambridge and Alliston for 2016.
The Appellant does not explain why the identified cost rate calculation for Cambridge and Alliston were excluded from the determination of the median Actual Cost Rate for the 2012 and 2016 assessment cycles. However, neither MPAC nor the Municipalities have disputed the Appellant’s evidence.
18The Board accepts the Appellant’s evidence as it has not been disputed by the other parties.
Method to determine quantum of Equitable Reduction
Introduction
19In the Interim Decision, the Board found that it would be inaccurate to simply compare the assessed current value of the Subject Property to the assessed current value of the similar properties, because not all components of the Cost Approach calculation are relevant points of comparison.
20The method discussed by the Board in the Interim Decision, is to determine whether different values were applied for the relevant points of comparison. An equitable reduction may be required, if the values used to calculate the current value of the similar properties are lower than those used to calculate the current value of the Subject Property. For example, as noted above, the construction cost rates used to calculate the current values of the similar properties are lower than the rates used to calculate the current value of the Subject Property.
21However, as noted in the Interim Decision, s. 44(3)(b) of the Act does not prescribe a specific methodology. As discussed in greater detail below, MPAC and the Municipalities have adopted an approach where they calculated the current value of each similar property applying the Model Approach, using the same rates as those used to calculate the current value of the Subject Property (“the revised current value”). They then compared this revised current value to the similar property’s assessed value as shown on the assessment roll (“the actual current value”). If the actual current value shown on the assessment roll is lower than the recalculated current value, this would indicate that the similar properties have been assessed at lower values as compared to the Subject Property, which, in turn, suggests that an equitable adjustment is required.
22The Appellant has applied a different approach. For each assessment cycle, the Appellant calculates the current value of the Subject Property using the Model Approach, utilizing the Actual Average Cost Rate for that cycle. As the Actual Average Cost Rate for each assessment cycle is lower than the Average Replacement Cost Per Square Foot applied by the Board for each assessment cycle, this results in lower current values of the Subject Property for all three assessment cycles. The Appellant maintains that there should be an equitable reduction of the Subject Property’s correct current value to these lower values. The Appellant also asserts that there should be a further equitable reduction, described as an “Additional Adjustment”, which is discussed in greater detail below.
MPAC’s evidence and position
23MPAC has summarized its analysis for the three assessment cycles in the following tables:
2008 Assessment Cycle
| Plant | Revised CVA (Using Model Approach) | Returned CVA | Ratio |
|---|---|---|---|
| Woodstock | $169,503,407 | $121,093,000 | 0.71 |
| Cambridge | $189,430,830 | $158,736,000 | 0.84 |
| Alliston | $222,411,278 | $109,600,000 | 0.49 |
| Oakville | $109,553,850 | $139,901,000 | 1.28 |
| Windsor | $58,841,645 | $65,000,000 | 1.10 |
| Brampton | $127,977,968 | $102,000,000 | 0.80 |
| Oshawa | $161,443,979 | $150,000,000 | 0.93 |
| Median | 0.84 |
2012 Assessment Cycle
| Plant | Revised CVA (Using Model Approach) | Returned CVA | Ratio |
|---|---|---|---|
| Woodstock | $236,210,210 | $145,000,000 | 0.61 |
| Cambridge | $222,089,143 | $187,197,000 | 0.84 |
| Alliston | $297,872,077 | $174,289,000 | 0.59 |
| Oakville | $169,286,983 | $116,000,000 | 0.69 |
| Windsor | $74,964,218 | $75,000,000 | 1.00 |
| Brampton | $183,167,798 | $115,000,000 | 0.63 |
| Oshawa | $205,312,793 | $133,730,000 | 0.65 |
| Median | 0.65 |
2016 Assessment Cycle
| Plant | Revised CVA (Using Model Approach) | Returned CVA | Ratio |
|---|---|---|---|
| Woodstock | $233,578,978 | $169,000,000 | 0.72 |
| Cambridge | $208,698,227 | $202,607,000 | 0.97 |
| Alliston | $258,907,053 | $190,632,000 | 0.74 |
| Oakville | $123,278,377 | $126,377,000 | 1.03 |
| Windsor | $59,113,099 | $65,000,000 | 1.10 |
| Brampton | $114,015,514 | $108,358,000 | 0.95 |
| Oshawa | $183,076,525 | $98,000,000 | 0.54 |
| Median | 0.95 |
24In the above table, the Ratio is the mathematical ratio of the Returned CVA to the Revised CVA. For example, Woodstock’s Returned CVA is 72% of the Revised CVA. Stated another way, the Revised CVA must be reduced by 28% (100 – 72) to arrive at the Returned CVA. MPAC asserts that this is the percentage reduction that should be used to determine the quantum of the equitable adjustment to be applied to the Subject Property.
25In summary, it is MPAC’s position that appropriate equitable adjustment, expressed as a percentage reduction of the correct current value of the Subject Property, is:
- 16% for the 2008 assessment cycle;
- 35% for the 2012 assessment cycle; and
- 5% for the 2016 assessment cycle.
Municipalities’ evidence and position
26The Municipalities adopted the average value, instead of the median value, in determining the percentage adjustment to achieve equity. Also, the Municipalities reported the land value separately. Therefore, the following tables report the calculated value of only the CAMI Facility, together with the percentage difference between the calculated value of the CAMI Facility and its assessed value as returned on the assessment roll.
2008 Assessment Cycle
| Plant | Model Approach | Difference |
|---|---|---|
| FCA Windsor | $63,257,531 | -2.0% |
| Toyota Woodstock | $150,236,341 | -38.8% |
| Ford Oakville | $73,965,105 | 9.0% |
| FCA Brampton | $90,187,375 | -28.3% |
| GM Oshawa | $121,721,445 | -3.6% |
| Honda Alliston | $193,660,501 | -51.5% |
| Toyota Cambridge | $162,368,332 | -25.7% |
| Average | -20.1% |
2012 Assessment Cycle
| Plant | Model Approach | Difference |
|---|---|---|
| FCA Windsor | $88,780,854 | -20.6% |
| Toyota Woodstock | $222,176,878 | -45.4% |
| Ford Oakville | $103,270,506 | -14.9% |
| FCA Brampton | $112,547,188 | -24.1% |
| GM Oshawa | $182,133,945 | -40.6% |
| Honda Alliston | $263,442,703 | -43.3% |
| Toyota Cambridge | unresolved | unresolved |
| Average | -31.5% |
2016 Assessment Cycle
| Plant | Model Approach | Difference |
|---|---|---|
| FCA Windsor | $77,946,224 | -24.9% |
| Toyota Woodstock | $216,004,886 | -25.4% |
| Ford Oakville | $92,577,039 | -8.7% |
| FCA Brampton | $100,303,433 | -26.0% |
| GM Oshawa | $141,301,588 | -34.3% |
| Honda Alliston | unresolved | |
| Toyota Cambridge | unresolved | |
| Average | -23.9% |
27It is the Municipalities’ position that the Board should reduce the correct current value by:
- 20.1% for the 2008 assessment cycle;
- 31.5% for the 2012 assessment cycle; and
- 23.9% for the 2016 assessment cycle.
The Appellant’s evidence and position
28The Appellant asserts that the correct current values of the Subject Property should first be reduced to the “Lower Current Values”. The Appellant calculated these values by applying the Model Approach, using the Actual Average Cost Rate to calculate the Replacement Cost New. The Appellant has provided a summary of its calculations, which is reproduced below (the “Appellant’s Summary”).
APPELLANT’S SUMMARY
29MPAC and the Municipalities expressed the equitable adjustment as a percentage of the correct current value of the Subject Property, whereas the Appellant did not. In order to compare the positions of all three parties, the Board has completed the calculations to express the Appellant’s proposed equitable reduction as a percentage reduction of the correct current value, as shown in the table below. It should be noted that the calculations are based only on the “Revised CVA” values shown in the Appellant’s Summary.
APPELLANT’S PROPOSED PERCENTAGE REDUCTIONS
| TAXATION YEAR | AGREED CURRENT VALUE | LOWER CURRENT VALUE | DIFFERENCE | PERCENTAGE DIFFERENCE |
|---|---|---|---|---|
| 2009 - 2012 | $77,591,470 | $48,934,000 | $28,657,470 | 36.9% |
| 2013 - 2016 | $99,285,244 | $71,606,000 | $27,679,244 | 27.9% |
| 2017 | $100,463,728 | $76,474,000 | $23,989,728 | 23.9% |
| 2018 - 2021 | $116,757,608 | $88,781,000 | $27,976,608 | 24.0% |
| 2022 | $123,817,543 | $96,625,000 | $27,192,543 | 22.0% |
30The Appellant also asserts that an Additional Adjustment is required. The Appellant undertook an analysis of the difference between MPAC’s assessment of the current values returned in the general reassessment for each of the similar properties for the three assessment cycles, and compared these assessed values to the “final” current value reported on the assessment roll.
31The Appellant has provided a summary of this data. For each assessment cycle, the Appellant has calculated the average percentage adjustment made for the similar properties. These averages indicate that the “final” current value is less than the current value returned by MPAC in its general reassessment. The Appellant asserts that this average percentage reduction should be applied to the Lower Current Values determined above. The Appellant describes it as an “Additional Adjustment”.
2008 CVA
| Plant | MPAC Calculated CVA | Final CVA | Additional Adjustment | |
|---|---|---|---|---|
| Brampton | $113,591,000 | $102,000,000 | -$11,591,000 | -10.2% |
| Windsor | $84,536,000 | $65,000000 | -$19,536,000 | -23.1% |
| Oakville | $139,901,000 | $116,000,000 | -$23,901,000 | -17.1% |
| Oshawa | $207,326,000 | $145,000,000 | -$62,326,000 | -30.1% |
| Alliston | $109,600,000 | $109,600,000 | $0 | 0.0% |
| Cambridge | $165,690,000 | $158,736,000 | -$6,954,000 | -4.2% |
| Woodstock | $119,000,000 | $119,000,000 | $0 | 0.0% |
| Median – All Plants | -10.2% |
2012 CVA
| Plant | MPAC Calculated CVA | Final CVA | Additional Adjustment | |
|---|---|---|---|---|
| Brampton | $194,053,000 | $115,000,000 | -$79,053,000 | -40.7% |
| Windsor | $103,107,000 | $75,000,000 | -$28,107,000 | -27.3% |
| Oakville | $192,043,000 | $116,000,000 | -$76,043,000 | -39.6% |
| Oshawa | $217,787,000 | $133,760,000 | -$84,027,000 | -38.6% |
| Alliston | $174,289,000 | $174,289,000 | $0 | 0.0% |
| Cambridge | $187,197,000 | TBD | TBD | TBD |
| Woodstock | $173,862,000 | $145,000,000 | -$28,862,000 | -16.6% |
| Median – All Plants (excluding Cambridge) | -32.9% |
2016 CVA
| Plant | MPAC Calculated CVA | Current CVA | Additional Adjustment | |
|---|---|---|---|---|
| Brampton | $184,858,000 | $108,358,000 | -$76,500,000 | -41.4% |
| Windsor | $77,958,000 | $65,000,000 | -$12,958,000 | -16.6% |
| Oakville | $206,016,000 | $126,377,000 | -$79,639,000 | -38.7% |
| Oshawa | $188,485,000 | $126,981,000 | -$64,504,000 | -32.6% |
| Alliston | $208,267,000 | TBD | TBD | TBD |
| Cambridge | $202,362,000 | TBD | TBD | TBD |
| Woodstock | $230,286,000 | $176,852,000 | -$53,434,000 | -23.2% |
| Median – All Plants (excluding Cambridge & Alliston) | -32.6% |
Findings
Applicable Equitable Reduction
32The Board first turns to the approach adopted by MPAC and the Municipalities. Regarding MPAC’s inclusion of land values, the Board assumes that the land values used in the recalculation of current value and in the current value as shown on the assessment roll would be the same, so inclusion of the land value would not impact MPAC’s calculation of the percentage reduction.
33MPAC and the Municipalities calculated different current values for each similar property used in the Model Approach, and consequently their recommended percentages for equitable reduction varies. The Board is unable to provide an explanation for the difference, as the Municipalities did not provide a detailed description of their calculations.
34The Board accepts that there is some merit to the approach taken by both MPAC and the Municipalities, in that it shows that the revised current values of the similar properties are generally higher than their assessed value as reflected on the assessment roll, which does suggest that an equitable reduction is required.
35However, the question remains as to what the quantum of the reduction should be. The current values calculated by MPAC are not the same as those calculated by the Municipalities. The Board finds that this evidence does not clearly indicate that these calculated values are incorrect. However, given the variances, there is an element of subjectivity respecting the percentage reductions presented by MPAC and the Municipalities.
36The Board also notes that MPAC and the Municipalities rely on a median or average value. In this case, there is only a small number of similar properties, and there is a significant degree of variance in the percentage reductions indicated for each of these similar properties. This raises a concern that the average or mean values may not be representative of the group, which, in turn, raises a concern that the average or median value may not be a reliable metric to determine the quantum of the equitable reduction.
37The Appellant’s approach, on the other hand, focusses on a specific similar point of comparison - the average construction cost rates used to determine Replacement Cost New. It is not disputed that lower construction cost rates were applied by MPAC for the similar properties for all three cycles (with the possible exception of the Brampton plant for the 2016 assessment cycle). Therefore, the Subject Property has clearly been assessed differently from similar properties based on this relevant point of comparison.
38The Board has prepared the following table summarizing the proposed percentage reductions advanced by all three parties:
| PARTY | 2009 - 2012 | 2013 - 2016 | 2017 | 2018 - 2021 | 2022 |
|---|---|---|---|---|---|
| MPAC | 16% | 35.1% | 5% | ||
| MUNICIPALITIES | 20.1% | 31.5% | 23.9% | ||
| APPELLANT | 36.9% | 27.9% | 23.9% | 24.0% | 22.0% |
39As noted above, all parties agree that an equitable reduction is required. They only disagree on what the quantum of the reduction should be. Section 44(3)(b) of the Act does not prescribe any specific methodology for determining quantum of equitable reduction, and states only that the Board “have reference to the value at which similar lands in the vicinity are assessed …”. The determination of whether an equitable reduction of current value is required, and, if so, the quantum of the reduction to be applied, is not a precise science. Consequently, the Board’s decision must be based on a qualitative evaluation of the evidence provided, an evaluation that is as objective as possible given the nature of the evidence before the Board.
40Although there is significant variance in MPAC's values for the 2008 and 2016 assessment cycles, and in the Appellant’s value for the 2008 assessment cycle, there is otherwise some consistency in the quantum of reductions advanced by each of the parties.
41Due to the somewhat unique circumstances of this case, the calculation of the Replacement Cost New for the Subject Property has utilized a higher Average Construction Cost rate than the calculation of Replacement Cost New for the similar properties. The Board finds that this relevant point of comparison is the most accurate indicator of inequity in assessment. For this reason, the Board finds that the best evidence and approach to determine the quantum of equitable reduction is the approach presented by the Appellant. Therefore, the Board finds that the quantum of the equitable reduction should be based on the Appellant’s Proposed Percentage Reductions.
42With respect to the Additional Adjustment, the Appellant has not sufficiently explained how a change made to MPAC's general reassessment value is a relevant consideration for the s. 44(3)(b) analysis. There is no indication that the reductions in assessed values of the similar properties were themselves due to equitable reductions. Furthermore, MPAC, in its general reassessment, may have made data errors respecting the similar properties’ physical characteristics, or in any of the components of the Cost Approach, such as the values for excess capital costs or functional obsolescence, or special site-specific considerations affecting the value for physical deterioration. Therefore, a reduction of a similar property’s current value as determined by MPAC in a general reassessment is not, in and of itself, a reliable indicator that the Subject Property has been inequitably assessed as compared to the similar properties.
43To establish inequity, the Appellant would need to establish that: (i) a specific reduction was applied when determining the assessed current value for a significant number of similar properties, and (ii) such reduction was not applied when determining the assessed current value of the Subject Property. Simply providing data which shows that the general reassessment values of the similar properties were reduced, without establishing and explaining the reasons for those reductions, is insufficient evidence to establish that there has been an inequity in the assessment of the Subject Property.
44For these reasons, the Board does not accept that the Additional Adjustments should be applied.
Additional Required Information
45As the parties did not provide the correct current value of the Subject Property for the deemed appeal for the 2023 taxation year, the Board has assumed that it is the same as for the 2022 taxation year. Furthermore, the parties did not specify classification apportionments for any of the taxation years. Consequently, the Board directs the parties to provide confirmation of the correct current value for the 2023 taxation year, together with confirmation of the apportionments in the “Appeals Chart” attached as Schedule A to this Decision, and submit it to the Board Registrar within 30 days of the issuance of this Decision. The Registrar is directed to then proceed to administratively issue the Board’s decision for each taxation year.
46Should the parties confirm a different current value of the Subject Property for the 2023 taxation year, the Board will accept this value. If so, the parties are further directed to provide the Board Register with the revised quantum for equitable reduction and the revised assessed value to be reported on the assessment roll for the 2023 taxation year.
ORDER
47The Board orders that:
- The current values of the Subject Property for the 2009 to 2022 taxation years under appeal are as follows:
| Taxation Year | Current Values |
|---|---|
| 2009 - 2012 | $77,591,470 |
| 2013 - 2016 | $99,285,244 |
| 2017 | $100,463,728 |
| 2018 - 2021 | $116,757,608 |
| 2022 | $123,817,543 |
- Pursuant to s. 44(3)(b) of the Act the Board applies the following reductions to the current values for the taxation years under appeal:
| Taxation Year | Equitable Reduction |
|---|---|
| 2009 - 2012 | $28,657,470 |
| 2013 - 2016 | $27,679,244 |
| 2017 | $23,989,728 |
| 2018 - 2021 | $27,976,608 |
| 2022 | $27,192,543 |
- The assessed values to be returned on the assessment roll for the taxation years under appeal are as follows:
| Taxation Year | Assessed Value |
|---|---|
| 2009 - 2012 | $48,934,000 |
| 2013 - 2016 | $71,606,000 |
| 2017 | $76,474,000 |
| 2018 - 2021 | $88,781,000 |
| 2022 | $96,625,000 |
- For the 2023 taxation year, the Parties are directed to provide the Registrar with: (i) the correct current value of the Subject Property; (ii) the quantum of equitable reduction determined using the Appellant’s method as accepted by the Board; and (iii) the resulting Assessed Value for the 2023 taxation year. Within 30 days of the issuance of this Decision, the Parties are further directed to provide the Registrar with confirmation of the apportionments, by providing this information in the “Appeals Chart” attached as Schedule A to this Decision. The Registrar is directed to then proceed to administratively issue the Board’s decision for each taxation year.
"Dirk VanderBent"
DIRK VANDERBENT
VICE-CHAIR
Assessment Review Board
Website: www.tribunalsontario.ca/arb
SCHEDULE A
| Appeal Number | Tax Year | Section Number | Effective Date | Classification | Value | Classification Confirmed | Apportionment Value: Confirm Or Change to: |
|---|---|---|---|---|---|---|---|
| 3211-011-020-41400-0000 | |||||||
| 2024806 | 2009 | 40 | January 1, 2009 | Large Industrial (Full) | $10,564,287 | Classification Confirmed | |
| Large Industrial (Excess Land) | $509,530 | Classification Confirmed | |||||
| TOTAL VALUE | $11,073,817 | ||||||
| 2343868 | 2010 | 40 | January 1, 2010 | Large Industrial (Full) | $10,564,287 | Classification Confirmed | |
| Large Industrial (Excess Land) | $509,530 | Classification Confirmed | |||||
| TOTAL VALUE | $11,073,817 | ||||||
| 2834860 | 2011 | 33 | June 2, 2010 | Large Industrial (Full) | $86,400 | Classification Confirmed | |
| 2834861 | 2011 | 33 | July 30, 2010 | Large Industrial (Full) | $153,600 | Classification Confirmed | |
| 2692004 | 2011 | 40 | January 1, 2011 | Large Industrial (Full) | $10,564,287 | Classification Confirmed | |
| Large Industrial (Excess Land) | $509,530 | Classification Confirmed | |||||
| TOTAL VALUE | $11,073,817 | ||||||
| 2834862 | 2011 | 33 | January 1, 2011 | Large Industrial (Full) | $240,000 | Classification Confirmed | |
| 2921001 | 2012 | 40 | January 1, 2012 | Large Industrial (Full) | $10,804,287 | Classification Confirmed | |
| Large Industrial (Excess Land) | $509,530 | Classification Confirmed | |||||
| TOTAL VALUE | $11,313,817 | ||||||
| 2949275 | 2013 | 40 | January 1, 2013 | Large Industrial (Full) | $14,110,700 | Classification Confirmed | |
| Large Industrial (Excess Land) | $606,000 | Classification Confirmed | |||||
| TOTAL VALUE | $14,716,700 | ||||||
| 3027377 | 2014 | 40 | January 1, 2014 | Large Industrial (Full) | $14,110,700 | Classification Confirmed | |
| Large Industrial (Excess Land) | $606,000 | Classification Confirmed | |||||
| TOTAL VALUE | $14,716,700 | ||||||
| 3091501 | 2015 | 40 | January 1, 2015 | Large Industrial (Full) | $14,110,700 | Classification Confirmed | |
| Large Industrial (Excess Land) | $606,000 | Classification Confirmed | |||||
| TOTAL VALUE | $14,716,700 | ||||||
| 3158186 | 2016 | 40 | January 1, 2016 | Large Industrial (Full) | $14,110,700 | Classification Confirmed | |
| Large Industrial (Excess Land) | $606,000 | Classification Confirmed | |||||
| TOTAL VALUE | $14,716,700 | ||||||
| 3237721 | 2017 | 40 | January 1, 2017 | Large Industrial (Full) | $13,139,800 | Classification Confirmed | |
| Large Industrial (Excess Land) | $564,200 | Classification Confirmed | |||||
| TOTAL VALUE | $13,704,000 | ||||||
| 3337457 | 2018 | 33 | July 15, 2017 | Large Industrial (Full) | $21,796,000 | Classification Confirmed | |
| 3312687 | 2018 | 40 | January 1, 2018 | Large Industrial (Full) | $13,139,800 | Classification Confirmed | |
| Large Industrial (Excess Land) | $564,200 | Classification Confirmed | |||||
| TOTAL VALUE | $13,704,000 | ||||||
| 3320586 | 2018 | 32 | January 1, 2018 | Large Industrial (Full) | $11,225,800 | Classification Confirmed | |
| Large Industrial (Excess Land) | $564,200 | Classification Confirmed | |||||
| TOTAL VALUE | $11,790,000 | ||||||
| 3337458 | 2018 | 33 | January 1, 2018 | Large Industrial (Full) | $21,796,000 | Classification Confirmed | |
| 3366193 | 2019 | 40 | January 1, 2019 | Large Industrial (Full) | $33,021,800 | Classification Confirmed | |
| Large Industrial (Excess Land) | $564,200 | Classification Confirmed | |||||
| TOTAL VALUE | $33,586,000 | ||||||
| 3410091 | 2020 | 40 | January 1, 2020 | Large Industrial (Full) | $33,021,800 | Classification Confirmed | |
| Large Industrial (Excess Land) | $564,200 | Classification Confirmed | |||||
| TOTAL VALUE | $33,586,000 | ||||||
| 3448061 | 2021 | 40 | January 1, 2021 | Large Industrial (Full) | $33,021,800 | Classification Confirmed | |
| Large Industrial (Excess Land) | $564,200 | Classification Confirmed | |||||
| TOTAL VALUE | $33,586,000 | ||||||
| 3218-030-065-31100-0000 | |||||||
| 2024946 | 2009 | 40 | January 1, 2009 | Large Industrial (Excess Land) | $2,038,122 | Classification Confirmed | |
| Residential (Full) | $724,547 | Classification Confirmed | |||||
| Farm (Full) | $105,600 | Classification Confirmed | |||||
| Commercial (Full) | $4,758,374 | Classification Confirmed | |||||
| Large Industrial (Full) | $42,257,146 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $15,394 | Classification Confirmed | |||||
| TOTAL VALUE | $49,899,183 | ||||||
| 2344073 | 2010 | 40 | January 1, 2010 | Large Industrial (Excess Land) | $2,038,122 | Classification Confirmed | |
| Residential (Full) | $724,547 | Classification Confirmed | |||||
| Farm (Full) | $105,600 | Classification Confirmed | |||||
| Commercial (Full) | $4,758,374 | Classification Confirmed | |||||
| Large Industrial (Full) | $42,257,146 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $15,394 | Classification Confirmed | |||||
| TOTAL VALUE | $49,899,183 | ||||||
| 2834863 | 2011 | 33 | June 2, 2010 | Large Industrial (Full) | $345,600 | Classification Confirmed | |
| 2834864 | 2011 | 33 | July 30, 2010 | Large Industrial (Full) | $614,400 | Classification Confirmed | |
| 2692045 | 2011 | 40 | January 1, 2011 | Large Industrial (Excess Land) | $2,038,122 | Classification Confirmed | |
| Residential (Full) | $830,147 | Classification Confirmed | |||||
| Commercial (Full) | $4,758,374 | Classification Confirmed | |||||
| Large Industrial (Full) | $42,257,146 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $15,394 | Classification Confirmed | |||||
| TOTAL VALUE | $49,899,183 | ||||||
| 2834865 | 2011 | 33 | January 1, 2011 | Large Industrial (Full) | $960,000 | Classification Confirmed | |
| 2920926 | 2012 | 40 | January 1, 2012 | Large Industrial (Excess Land) | $2,038,122 | Classification Confirmed | |
| Residential (Full) | $830,147 | Classification Confirmed | |||||
| Commercial (Full) | $4,758,374 | Classification Confirmed | |||||
| Large Industrial (Full) | $43,217,146 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $15,394 | Classification Confirmed | |||||
| TOTAL VALUE | $50,859,183 | ||||||
| 3046741 | 2013 | 40 | January 1, 2013 | Large Industrial (Excess Land) | $2,424,000 | Classification Confirmed | |
| Residential (Full) | $1,012,500 | Classification Confirmed | |||||
| Commercial (Full) | $6,565,300 | Classification Confirmed | |||||
| Large Industrial (Full) | $56,442,700 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $29,800 | Classification Confirmed | |||||
| TOTAL VALUE | $66,474,300 | ||||||
| 3046742 | 2014 | 40 | January 1, 2014 | Large Industrial (Excess Land) | $2,424,000 | Classification Confirmed | |
| Residential (Full) | $1,012,500 | Classification Confirmed | |||||
| Commercial (Full) | $6,565,300 | Classification Confirmed | |||||
| Large Industrial (Full) | $56,442,700 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $29,800 | Classification Confirmed | |||||
| TOTAL VALUE | $66,474,300 | ||||||
| 3091343 | 2015 | 40 | January 1, 2015 | Large Industrial (Excess Land) | $2,424,000 | Classification Confirmed | |
| Residential (Full) | $1,012,500 | Classification Confirmed | |||||
| Commercial (Full) | $6,565,300 | Classification Confirmed | |||||
| Large Industrial (Full) | $56,442,700 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $29,800 | Classification Confirmed | |||||
| TOTAL VALUE | $66,474,300 | ||||||
| 3158437 | 2016 | 40 | January 1, 2016 | Large Industrial (Excess Land) | $2,424,000 | Classification Confirmed | |
| Residential (Full) | $1,012,500 | Classification Confirmed | |||||
| Commercial (Full) | $6,565,300 | Classification Confirmed | |||||
| Large Industrial (Full) | $56,442,700 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $29,800 | Classification Confirmed | |||||
| TOTAL VALUE | $66,474,300 | ||||||
| 3278908 | 2017 | 40 | January 1, 2017 | Large Industrial (Excess Land) | $2,257,200 | Classification Confirmed | |
| Residential (Full) | $942,800 | Classification Confirmed | |||||
| Commercial (Full) | $6,113,700 | Classification Confirmed | |||||
| Large Industrial (Full) | $52,560,600 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $27,700 | Classification Confirmed | |||||
| TOTAL VALUE | $61,902,000 | ||||||
| 3312850 | 2018 | 40 | January 1, 2018 | Large Industrial (Excess Land) | $2,257,200 | Classification Confirmed | |
| Residential (Full) | $942,800 | Classification Confirmed | |||||
| Commercial (Full) | $6,113,700 | Classification Confirmed | |||||
| Large Industrial (Full) | $52,560,600 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $27,700 | Classification Confirmed | |||||
| TOTAL VALUE | $61,902,000 | ||||||
| 3320587 | 2018 | 32 | January 1, 2018 | Large Industrial (Excess Land) | $2,257,200 | Classification Confirmed | |
| Residential (Full) | $942,800 | Classification Confirmed | |||||
| Commercial (Full) | $6,113,700 | Classification Confirmed | |||||
| Large Industrial (Full) | $44,906,600 | Classification Confirmed | |||||
| TOTAL VALUE | $54,220,300 | ||||||
| 3365971 | 2019 | 40 | January 1, 2019 | Large Industrial (Excess Land) | $2,257,200 | Classification Confirmed | |
| Residential (Full) | $942,800 | Classification Confirmed | |||||
| Commercial (Full) | $6,113,700 | Classification Confirmed | |||||
| Large Industrial (Full) | $44,906,600 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $27,700 | Classification Confirmed | |||||
| TOTAL VALUE | $54,248,000 | ||||||
| 3410193 | 2020 | 40 | January 1, 2020 | Large Industrial (Excess Land) | $2,257,200 | Classification Confirmed | |
| Residential (Full) | $942,800 | Classification Confirmed | |||||
| Commercial (Full) | $6,113,700 | Classification Confirmed | |||||
| Large Industrial (Full) | $44,906,600 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $27,700 | Classification Confirmed | |||||
| TOTAL VALUE | $54,248,000 | ||||||
| 3448292 | 2021 | 40 | January 1, 2021 | Large Industrial (Excess Land) | $2,257,200 | Classification Confirmed | |
| Residential (Full) | $942,800 | Classification Confirmed | |||||
| Commercial (Full) | $6,113,700 | Classification Confirmed | |||||
| Large Industrial (Full) | $44,906,600 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $27,700 | Classification Confirmed | |||||
| TOTAL VALUE | $54,248,000 | ||||||
| 3490238 | 2022 | 40 | January 1, 2022 | Commercial (Excess Land) | $219,100 | Classification Confirmed | |
| Large Industrial (Excess Land) | $138,500 | Classification Confirmed | |||||
| Residential (Full) | $3,283,300 | Classification Confirmed | |||||
| Commercial (Full) | $7,811,300 | Classification Confirmed | |||||
| Large Industrial (Full) | $88,512,400 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $26,400 | Classification Confirmed | |||||
| TOTAL VALUE | $99,991,000 | ||||||
| 3513828 | 2023 | 40 | January 1, 2023 | Commercial (Excess Land) | $219,100 | Classification Confirmed | |
| Large Industrial (Excess Land) | $138,500 | Classification Confirmed | |||||
| Residential (Full) | $3,283,300 | Classification Confirmed | |||||
| Commercial (Full) | $7,811,300 | Classification Confirmed | |||||
| Large Industrial (Full) | $88,512,400 | Classification Confirmed | |||||
| Exempt (Non-assessable unit) | $26,400 | Classification Confirmed | |||||
| TOTAL VALUE | $99,991,000 |