Brown J, for the majoirty, indicated that substantial deference should be given to the specialized expertise of the Canadian International Trade Tribunal, whereas Côté J, after noting that the Customs Tariff Schedule before the Court precisely implemented an international Convention, stated (at para. 58):
Given the Convention parties’ intention of creating a uniform classification scheme, I find that the range of reasonable statutory interpretations in this context is narrow.
|Locations of other summaries||Wordcount|
|Tax Topics - Other Legislation/Constitution - Federal - Customs Tariff Act - Schedules - General Rules for the Interpretation of the Harmonized System - Rule 2 - Rule 2(b)||good must be described in headings - even if not ultimately included therein because of their composite nature — before Rule 2 can apply||783|
|Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions||an “includes” definition could reasonably be viewed as being limited by the listed items||208|