Dickson, J:—Two issues are raised in this appeal: the first, a constitutional question as to provincial competence to tax a resident beneficiary to whom property situate outside the province has passed on the death of a person domiciled outside the

Abbott, J. (all concur) :—The appellant, a solicitor who has practised law in the City of Toronto since 1928, was at all material times a member of the firm Mackenzie, Wood & Goodchild. That firm had a general practice which included a ‘‘fairly substantial