Addy, J:—This case was heard by me immediately following that of the Bank of Nova Scotia and involved the same legal issues. The only factual differences were the following:
1. The taxation involved the fiscal year of the plaintiff ending the 31st of October, 1974.
2. The weighted average rate of translation was 2.30894 Canadian dollars to the pound sterling and the amount of United Kingdom tax paid was £1,411,890.48.
It was agreed by both parties that the arguments and legal considerations to be applied were absolutely identical to those in the aforesaid Bank of Nova Scotia case.
For the reasons mentioned in that case, a copy of which is hereto annexed, the appeal is allowed and the matter is referred back to the Minister of National Revenue for reassessment in accordance with the above- mentioned figures and my legal findings in the aforesaid Bank of Nova Scotia case.
The plaintiff will be entitled to its costs.
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