Law360 Canada ( July 20, 2018, 8:08 AM EDT) -- Appeal by City Centre Equity and two others from a decision by the Assessment Appeals Committee of the Saskatchewan Municipal Board of Revision. The City of Regina assessed commercial office buildings using an income approach. The median capitalization rate in respect of the net rental income stream was determined using six comparable sales, including the sale by Saskatchewan Government Insurance (SGI) of its one-third interest in a particular property, 1800 Hamilton, to another co-owner, SaskPen. The sale price of SGI’s interest was $13.8 million, representing one-third of a recent valuation. The appellant appealed its tax assessment to the Board of Revision on the basis the assessor erred by including the sale of 1800 Hamilton among properties used to determine the median capitalization rate. The appellant submitted that the sale occurred in the context of a non-arm’s length transaction and therefore the market valuation standard was not achieved. The Board accepted that the strategic links between SGI and SaskPen rendered the sale a non-arm’s length transaction, and that the sale should be removed from the median capitalization rate calculation. The City appealed. The Assessment Appeals Committee overturned the Board’s decision and restored the original assessment on the basis that the Board erred in excluding the sale. The Committee found the existence of an arm’s length transaction, as the parties were independent, the price was determined by a reputable appraisal, and cash changed hands. The appellants appealed....