Words and Phrases - "less"
Canterra Energy Ltd. v. The Queen, 87 DTC 5019,  1 CTC 89 (FCA)
Prior to the introduction of s. 257, the word "minus" in what was then regulation 1207(2)(a)(ii) was held to have been used in its algebraic sense, with the result that the amount determined for the taxpayer pursuant to that regulation was a negative amount. Since regulation 1207(2)(a) was in essence a formula, the word "minus" should be interpreted in its mathematical sense. Urie JA stated:
It is not used in its non-technical sense in which, no matter what non-technical meaning is attributed to it, it is compared in all the dictionaries to which we were referred, to the word “less”. That word clearly implies a subtraction of something from the whole and does not contemplate the result being a negative amount.
That its use is technical in nature in subparagraph (ii) is demonstrated by the fact that as part of subsection 2 a double subtraction is involved.
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