I am a Canadian inspector.
Based on the 19th edition of the CEC, a neutral would not be required in this instance.
The XO connection of the transformer being installed must be connected to the ground electrode via a copper conductor meeting the requirements of table 17.
I forgot to mention that a bonding conductor meeting the requirements of table 16 is also required for the transformer case and raceways.
[This message has been edited by Rick Kelly (edited 06-12-2006).]