LeBel J. stated (at para. 58):
"The Minister also relies on statements made in the House of Commons at the time of the addition of s.20(1)(f) to the ITA, and on Technical Notes issued by the Department of Finance to explain the addition of, and amendments to, s.20(1)(f). Putting aside the question of the weight that should be given to these interpretative aids, the difficulty with the Minister's arguments is that although both sources support the view that discounts were in the contemplation of Parliament when it enacted s.20(1)(f), neither goes so far as to suggest that s.20(1)(f) is restricted to discounts. Since this is the very restriction the respondents are contesting, the interpretative aids invoked by the Minister are not dispositive of the issue, although they may shed some light on Parliament's intention."