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J.D.L. itself received the goods which it shipped to the respondent, from its U.S. parent, Deere & Comapny, on consignment in accordance with a written agreement between them. ... H.C.); Re Librairie & Tabagie Aston Inc.; St.-Georges v. Agence de Distribution Populaire Inc. (1980), 35 C.B.R. ... I conclude that the o ^ I? f consignment intended as security within the meaning of s. 2 of the PPSA and that, therefore, no registration or other compliance with that statute was required on the part of Anglo. ...

R. [1] ’, decided after the trial judgment in the present case. The provision in question in that case, subsection 55(2) of the Income Tax Act, required for its application that “one of the purposes” be to support a significant reduction in capital gain realized. ...

.: — The appeal raises two questions. 1. Were the amounts provided by the Government of Alberta to the respondent “assistance” as a grant, subsidy, forgiveable loan, deduction from tax, investment allowance or as any other form of assistance.... within the language of both subparagraph 12(l)(x)(iv) of the Income Tax Act, defining income, and of subsections 127(11.1) and 127(9) defining investment tax credits? ...

Counsel added that this interpretation was supported by the text services, or classes, grades or qualities thereof, the amount that may be deducted under this section is an amount equal to the lesser... (4) For the purposes of this section, (a) ‘allocation in proportion to patronage' for a taxation year means an amount credited by a taxpayer to a customer of that year... computed at a rate in relation to the quantity, quality or value of the goods or products... sold... to the customer... with appropriate differences in the rate for different classes, grades or qualities thereof... ” of the definition of the phrase “allocation in proportion to patronage” found in paragraph 135(4) which expressly specifies that, in the computation of the allocation, there may be "appropriate differences in the rate for different classes, grades or qualities thereof". ...

Wampole & Co., [1931] S.C.R. 494, [1931] 3 D.L.R. 754 at pages 496-97 (D.L.R. 754-55), the trial judge concluded, on the second issue, that the distribution of the directories by the appellant to its subscribers did amount, in the circumstances of this case, to a "use" of those goods within the meaning of subparagraph 27(1)(a)(iii). ...

Thill & Associates, which had in turn also received the necessary funds from Applied Research. ...

.: — The sole issue in this case is whether the respondent during its 1976 and 1977 taxation years manufactured or processed goods for sale or lease within the meaning of paragraph 125.1 (3)(a) of the Income Tax Act ("the Act") to entitle it to deduct from tax otherwise payable by it the manufacturing and processing tax credit provided by section 125.1 of the Act. ...

Her Majesty the Queen, [1996] 3 CTC 254 Hugessen J.A: — This is an appeal from a judgment which dismissed the appellant’s appeal of the Minister’s disallowance for the taxation years 1980 through 1983 of certain “soft” costs in relation to a Multiple Unit Residential Building (MURB) development in which the taxpayer had invested. ...

Accordingly, for all of the foregoing reasons the appeal will be dismissed with costs. 1 See, eg, Regal Heights Limited v MNR, [1960] S.C.R. 902;]1960[CTC 384; 60 DTC 1270; MNR v Foreign Power Securities Ltd,]1967[SCR 295; [1967] CTC 116; 67 DTC 5084; Warnford Court (Canada) Ltd v MNR, [1964] Ex CR 944; [1964] CTC 175; 64 DTC 5103; D C McDonald v The Queen, [1974] CTC 836; 74 DTC 6644. 2 + [1976] CTC at p 453. ...

If the employee chooses at some later date to acquire the shares, as the appellant did in the case at bar, any resulting benefit by virtue of paragraph (a) shall be deemed to have been received in the year of acquisition “... by the employee by virtue of his employment”. ... The option was granted “... in consideration of the optionee fulfilling the conditions...” set forth in the agreement. The option was “... an option to purchase 2,500 common shares of the capital stock of the Company upon the following terms and conditions...” ...