The Queen v. St. John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA) -- text
The Chief Justice:—The issue in this appeal is whether lump sum payments of $25,375, $75,000 and $81,875 made by the respondent in 1971, 1972 and 1973 respectively to Com/Code Corporation, a non-resident United States corporation, were amounts in respect