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British Columbia (Information & Privacy Commissioner) (1996), 140 D.L.R. (4th) 372 (B.C. ... In Eastwood & Co. v. Minister of National Revenue (1993), 94 D.T.C. 6411 (B.C. ... Boiler Inspection & Insurance Co. of Canada (April 3, 1995), Doc. ...

Pinto & Co., [1925] 1 K.B. 30, another case cited, is of the same genre as the Maclaine case and does not assist the respondent. I think that perhaps the root case here is Grainger & Son v. Gough, [1896] A.C. 825. ... The decision of Taylor, J. in Re Income Tax Act and Procter & Gamble, [1937] 3 W.W.R. 680, was relied on by the respondent. ...

The following cases were referred to by Revenue Canada: • Alberta (Provincial Treasurer) v. ... C.A.) • Discovery Trust Co. v. Abbott (1982), 38 B.C.L.R. 55 (B.C. S.C.) ° R. v. ... (as she then was) stated at page 56: … In Vancouver A & W Drive-Ins Ltd. v. ...

—Letters and other communications passing between a party, or his predecessors in title, and his, or their solicitors, are privileged from production, provided they are, and are sworn to be, confidential, and written to, or by, the solicitor in his professional capacity, and for the purpose of getting legal advice or assistance for the client. ’ ’ It will be noted that each of these definitions refers to the same thing as is referred to in Section 126A(1) (e), communications between solicitor and client. ...

Takahashi & Company Ltd. and Douglas Plywood Ltd. were faced with conflicting demands by the plaintiff and by the Department of National Revenue, Taxation Division, to certain moneys which they owed and would otherwise have paid to Canadian Plywood Corporation Ltd. ... (b) Canadian Plywood was at all times material indebted to the plaintiff and to the Crown Federal in amounts in excess of the total moneys in court. (¢) Takahashi and Douglas each owed the moneys in court to Canadian Plywood prior to April 15, 1970. ... &. C. en banc, per MacDonald, J.: Hence I think it is desirable to point out that the prerogative claimed by the Crown Dominion is that described in the Attorney- General’s factum herein as “the prerogative which provides that, whenever the right of the Crown and the right of the subject with respect to the payment of debts or claims of equal degree come into competition, the right of the Crown prevails... to the exclusion or postponement of other claimants of equal degree”. ...

However, the submission of the plaintiffs receives considerable support in judgments in the Supreme Court of Canada: City of Montreal v Montreal Light, Heat & Power Co (1909), 42 SCR 431. ... I refer firstly to the judgment of the California Court of Appeal, Second District, Terrace Water Co v San Antonio Light & Power Co et al (1905), 82 P 562. ... I decide this case on the basis that the Supreme Court of Canada in City of Montreal v Montreal Light Heat & Power Co, supra, has decided that electricity is a commodity and accepting the view expressed in People of State of Illinois v Menagas that electricity is personal property. ...

The clear question which I am asked to decide is whether the defendant Bourassa has a good defence under Section 126(6) of the Income Tax Act by reason of the words therein, ‘‘... unless he is unable to do so.’’ ...

The stated case reads as follows: “ James Stewart Tyhurst was charged that he did, on the 14th, 15th, 16th, 17th, 18th and 19th days of November, A.D. 1960, unlawfully fail to file T1 1959 Income Tax Return, after demand under Section 44(2) of the Income Tax Act contrary to Section 131(1) of the ‘Income Tax Act. ... The extent of this meaning here is made more conclusive by the marginal note of the subsection, viz., ‘‘ Proof of Service by Mail’’. ...

A licence fee of one dollar shall be payable in respect of each licence.” “6(1) Every Collector, constable, and every person authorized in writing by the Minister of Finance to exercise the powers of inspection under this section may without warrant enter upon any premises on which he has cause to believe that any fuel-oil is kept or had in possession, and may inspect the premises and all fuel-oil found thereon, and may interrogate any person who is found on the premises or who owns, occupies, or has charge of the premises. ‘ ‘ The question as to what taxation it is competent for the Provincial Legislature to impose is a legal one. ...

Bissell has specified the following “ public interest" grounds (summarized): 1. Disclosure of this information would be injurious to the relationship between employees of Revenue Canada and legal counsel in the Department of Justice — resulting in reluctance to consult and discouraging full and frank discussion; 2. ... I have already suggested that cross-examination of Revenue Canada officials will determine the appropriateness of the action taken — a suggestion reflecting the receipt of advice in what counsel for the Crown calls “the most routine and ordinary context”. ...