CARTWRIGHT, J. (dissenting) :—The facts out of which this appeal arises are stated in the reasons of my brother Abbott. The question for decision is whether the rebates totalling $483,185.91 given by Nuffield to the appellant in the course of the latter’s

Wilson, J.:—The issue to be determined in this appeal is whether interest earned by the appellant, Ensite Limited (“Ensite”), from United States dollar deposits in the Philippines qualifies as “foreign investment income” within the meaning of subsection 129(4) of

Hamlyn T.C.J.: