Csi Development Corp. v. R., 99 DTC 1139, [1999] 3 CTC 2421 (TCC) -- summary under Interpretation Bulletins, etc.

After noting that the capital dividend account definition in s. 89(1) was silent on the treatment of the non-taxable portion of a capital gain realized by a corporate partnership, and that IT-138R permitted a pro rata addition by a corporate partner to its capital dividend account, McArthur TCJ. stated (at p. 1143) that "while the Interpretation Bulletin does not have legislative authority, it is an important factor in interpreting the Act when there is a void".