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The precise scope of the residual category- windfall gains — has proven problematic. ...

., supra, at page 2278 (D.T.C. 271) (T.C.C.) where Bonner, T.C.C.J. stated: In my view the definition of “ principal residence" contained in paragraph 54(g) is such that considerations as to what can lawfully and effectively be conveyed are irrelevant. ...

Minister of Manpower & Immigration, [1978] 2 S.C.R. 375, 81 D.L.R. (3d) 687, at page 381 (D.L.R. 691). ...

. — rent, royalty or similar payment, including, butnotsoasto restrict the generality of the foregoing, any payment.... 3 The parties, through counsel, tendered an agreed statement of facts at trial (Exhibit 1). 4 Paragraph 883(a)(1) reads: (a) Income of foreign corporations from ships and aircraft.— The following items shall not be included in gross income of a foreign corporation, and shall be exempt from taxation under this subtitle: (I) Ships operated by certain foreign corporations.— Gross income derived by a corporation organized in a foreign country from the international operation of a ship or ships if such foreign country grants an equivalent exemption to corporations organized in the United States. 5 This “effective connection” is established by various factors, one of which, admittedly, is Norsk’s place of management. 6 Since this is a determination of foreign law, it is a finding of fact. ...

The separation of legal personality as between one acting in his personal capacity and the same person acting in his capacity qua executor or trustee is as distinct as that of an incorporated company and its chief shareholder: see Salomon v Salomon & Co. ...