Marginal Notes

Table of Contents


Canada v. CAMECO Corporation, 2020 FCA 112

marginal note referred to as indication of provision’s thrust

After referencing authorities on the relevance of headings including Supreme Court quotation of Driedger that headings "should be considered part of the legislation and should be read and relied on like any other contextual feature" (para. 58), Webb JA stated (at para. 60) that the “Transfer Pricing Adjustment” “heading” (i.e., marginal note) to s. 247(2) was indicative that it was primarily a pricing-adjustment rather than a recharacterization rule.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(b) s. 247(2)(b) did not apply to having long-term supply contract assigned to NR sub 460

Imperial Oil Ltd. v. Canada, 2004 DTC 6702, 2004 FCA 361, rev'd 2006 SCC 46

rev'd on other grounds 2006 SCC 46

LeBel J. stated (at para. 57):

"The Minister has even sought support for his position in the marginal notes, which refer to a 'discount'. Although marginal notes are not entirely devoid of usefulness, their value is limited for a court that must address a serious problem of statutory interpretation."