In response to a submission of the Minister that in the absence of a separate definition for the section, "income" had a different meaning in s. 106 of the Corporations Tax Act from its meaning in Part II of that Act in which the section appeared, Wilson J. stated:
"The difficulty with this position, as I see it, is that a taxing statute is a highly technical piece of legislation which requires an interpretation that will ensure certainty for the taxpayer. Many of the words used carry a very specific and technical meaning because they identify the fundamental concepts underpinning the legislation. 'Income' is one of those fundamental concepts."