Before finding that there was no inconsistency in the taxpayer being resident in Canada for purposes of the Act and a resident of the U.K. for purposes of the Canada-U.K Income Tax Convention, , Rip CJ stated (at para. 67):
In Friends of the Oldman River Society v. Canada (Minister of Transport), [1992] 1 S.C.R. 3, the Supreme Court held that for two statutes to be inconsistent they must either be so contradictory that following one law would require breaching the other or the two laws must be unable to stand together.