Webb J. found that a s. 118.5(1)(b)(i), which disallows deductions of fees for courses of study outside of Canada if they are "paid in respect of a course less than 13 consecutive weeks duration," did not apply in situations where the student took several consecutive courses over a period of at least 13 weeks. He reasoned (at para. 22) that the singular "course" includes the plural.
The Minister argued that there was evidence that Parliament drew a distinction between the singular and plural in this part of the Act - the definition of "qualifying educational program" in s. 118.6(1) requires that students "not spend less than ten hours per seek on courses for work in the program... ." Webb J. stated (at para. 24):
In this definition only the plural form of "courses" is used. It does not seem to me that a program would not be a qualifying educational program if it otherwise satisfies this definition but each student spends his or her time on only one course and not multiple courses. It seems to me that the use of the plural in this definition would include the singular and therefore it would seem logical that the use of the singular "a course" in subparagraph 118.5(1)(b)(i) of the Act would include the plural.