The recent decision in 1164708 B.C. Ltd. v. British Columbia (1164708 B.C. Ltd.) addressed the applicability of the additional property transfer tax (ATT), commonly known as the "foreign buyer tax," under British Columbia's Property Transfer Tax Act, R.S.B.C. 1996, c. 378 (PTT Act). This appeal involved a challenge by the appellant, 1164708 B.C. Ltd. (Petitioner), of a C$6-million reassessment of ATT that was levied by the Ministry of Finance in connection with an acquisition made by the Petitioner.