Stephen Longo

The Municipal Property Assessment Corporation appealed a decision declaring that properties leased by the Crown to non-profit Harbour Authorities for nominal rent were exempt from property taxation.

MPAC argued the Harbour Authorities paid valuable consideration through services and maintenance obligations.

The Divisional Court dismissed the appeal, finding no palpable and overriding error in the application judge's conclusion that the services did not constitute a profit to the Crown.

Furthermore, the Court held that the Harbour Authorities shared an identity of patrimony with the Crown, entitling them to the same tax exemption.