Rothstein, J.:—

Hamilton, J.:—Delbert Fisher, Joyce Fisher, and Aubrett Holdings Ltd. (hereinafter referred to as "Aubrett") stand charged with a total of 15 offences under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the

Reed, J.:—The defendant brings a motion to strike the plaintiff's claim for want of prosecution.

MacGuigan, J.A.:—The only issue on this appeal is whether a tax exemption granted by Puerto Rico to an affiliate of a Canadian corporation is an export incentive under Canadian income tax law. The trial judge (in Old HW- GW

McClung, Hetherington and Stratton, JJ.A.:—This appeal involves the interpretation of certain sections of the Alberta Corporate Income Tax Act, R.S.A. 1980, c. A-17 (now the Alberta Corporate Tax Act)

Strayer, J.:—

Létourneau, J.A. (Marceau, Robertson, JJ.A concurring):— Pursuant to Rule 474 of the Federal Court Rules, the parties had submitted the following question of law for a determination:

Dubé, J.:— The instant application by the taxpayer is for an order that payment be made into Court respecting income tax certificate ITA-7628-92 dated September 30, 1992, and that Revenue Canada file a discharge of the certificate presently registered against

Hutchinson, J.:— The appellant, Harvard International Resources Ltd., (HIRL) appeals pursuant to subsection 50(2) of the Alberta Corporate Income Tax Act, R.S.A. 1980, c. A-17, (the “Alberta Act") from two decisions of the

Tallis, J.A.:— In these consolidated appeals, we are confronted with the constitutionality of the garnishment provision found in subsection 224(1.2) of the Income Tax Act, S.C. 1970-71-72, c. 63 [enacted 1987, c. 46 section 66; amended,