Before finding that there was an ambiguity in s. 224(1.2) which should be resolved in favour of the taxpayer, Scott J.A. stated (p. 6179):
"While statutory 'ambiguity' is now resolved by looking to the purpose and rationale of the particular provision, the purpose rule has not displaced the plain meaning rule in tax law. Put another way, the purpose rule is only used where the statutory language of the provision under scrutiny is obscure or ambiguous".