In finding that revenue-producing assets did not have to be held for any minimum period of time or generate a relatively large amount of revenue in order to satisfy the requirements of Regulation 1102(1)(c), L'Heureux-Dubé J. stated (at pp. 5377-8):
"In as technical a piece of legislation as the ITA, had Parliament or the executive wanted to specify any minimum period of time, materiality requirement, or financial statement content requirement, they would have used clear language to that effect."