After referencing authorities on the relevance of headings including Supreme Court quotation of Driedger that headings "should be considered part...
|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
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...