88 C.R. - "Finance and Leasing" - "Leasing"

RC will normally rely on the assumption that the form of an agreement reflects the true relationship of the parties involved.

Since CCA accrues only to the owner of the property, where the transaction (having regard to the actual legal rights and obligations of the parties) is a lease, only the lessor is entitled to CCA, and where it is determined that the agreement results in a disposition and acquisition of property, only the party acquiring the property will be entitled to CCA. [C.R.: 54(c)]

The providing of a lease does not constitute the lending of money by the lessor to the lessee.