John – based on what I’ve experienced with CRA’s practices for distinguishing between an agency vs. non-agency disbursement, they seem to draw the line according to who is lawfully obligated to pay the cost. So if we look at land transfer taxes, this is a tax on the person acquiring real property – this would be recognized as an agency type payment. On the other hand, a title clearance certificate is relied on by a lawyer to give a legal opinion as to clear title when a person purchases the land and thus is not considered to be paid as an ‘agent’. In the case of property taxes, these are always imposed on the landowner, even though rental agreements will obligate the tenant to pay but ultimately the municipality can enforce payment on the landowner – therefore, CRA takes the view that payments of property taxes under a net lease arrangement are taxable as form of rent payment. As for most of the other disbursements in P-209R, I’m sure good arguments could be made either way but we’ll never have the satisfaction of knowing the outcome at the SCC.