Dube, J:—The basic issue in this action is whether or not the plaintiff in the taxation year 1972 was carrying on a business in a country other than Canada and thus not obligated to withhold the tax payable by a nonresident on interests

The Chief Justice:— This appeal is from a judgment of the Trial Division answering a question that had been set down for determination before trial under Rule 474. The action was brought by the respondent seeking declarations with respect

Gibson, J:—The Province of British Columbia established a sea bus system connecting North Vancouver with the Vancouver city centre, which system opened in 1977. The Province of British Columbia did this, according to the evidence, to provide a third crossing

Addy, J:—The action involves income tax assessed against the defendant for taxation years 1967 to 1970 inclusively, pursuant to reassessments made against it for certain gains realized from share and option transactions as well as interest received by the

Mahoney, J:—This is an appeal from the reassessment of the plaintiff’s 1977 income tax return. The trial was heard together and on common evidence with an appeal by the plaintiff’s wife from the reassessment of her 1977 return. Both plaintiffs are

Urie, J:—This is an appeal from a judgment of the Trial Division dismissing the appellant’s actions with respect to income tax reassessments made by the Minister of National Revenue in respect of the appellant’s 1973, 1974, 1975 and 1976 taxation years.

Smith, DJ:—The issues in these two cases are the same, save for differences in the amounts of money involved. It was agreed by the parties that the two cases be heard together and that the evidence given to the Court apply equally to

Gibson, J:—This appeal relates to the 1975, 1976, and 1977 taxation years of Timagami.

Pratte, J:—It is unnecessary for the purposes of this appeal to decide whether the decision of the Supreme Court of Canada in F Sura v MNR, [1962] CTC 1; 62 DTC 1005, must still be followed despite the changes that

Cattanach, J:—By notice dated April 30, 1976 the Minister of National Revenue reassessed the plaintiff by including in its income an amount of $652,976.37 for its 1973 taxation year.