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Stewart & Company Limited v. Minister of National Revenue, [1946] CTC 311 0 ‘CONNOR, J. ... In 1927 see. 10 of this Act read: " 19. On the winding up, discontinuance or reorganization of the business of any incorporated company, the distribution in any form of the property of the company shall be deemed to be the payment of a dividend to the extent that the company has on hand undistributed income.’’ ... Failure to pay the tax within the prescribed time shall render the company liable for interest thereon at that rate of six per centum per annum until paid. ‘ ‘ In 1934 see. 19 was amended by striking out the words "‘in the taxation period 1930 and subsequent periods’’, leaving the section as it stood in 1927. ...

Jacob Mayer & Sons Ltd. v. Minister of National Revenue, [1954] CTC 141, 54 DTC 1075 THORSON, P. ... Mayer & Sons. The business was entirely his and he owned all its assets. ... Mayer & Sons. A meeting of the directors followed immediately afterwards. ...

& S. duty September 10, 1957, $1,600.00, making a total of $5,067.42; March 31, 1956, to United China & Glass, $2,620.35, plus Canada S.S. Lines $219.23, plus Samson & Shaen, $1,302.61, making a total of $4,142.19; and June 6, 1956, to Shore & Coggins, $998.75. ... Wild, $1,570.09; and on July 6, 1956, to Shore & Coggins, $998.75. ...

Miron & Frères Limitée v. Minister of National Revenue, [1954] CTC 45, 54 DTC 1022 Fournier, J. ... Michel for the price of $90,000.00 and in 1949 he sold this property to Miron & Frères Limitée for the price of $600,000.00. ... The dispute between the parties is on the interpretation to be given to the words " " a corporation and one of several persons by whom it is directly or indirectly controlled shall be deemed not to deal at arm’s length’’. ...

O’reilly & Belanger, Limited v. Minister of National Revenue, [1917-27] CTC 332, [1920-1940] DTC 121 AUDETTE, J. ... & of sec. 3 of the Act which reads as follows: "" (8) In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of:— "(a) disbursements or expenses not wholly, exclusively and necessarily laid out or expended for the purpose of earning the income. ” These provisions of the statute, like those of the English Act. do not affirmatively state what disbursements and expenses may, be deducted, and there is in words no deductions allowed at ail unless indirectly. ... This argument, he says, would require the words *‘ wholly and exclusively’’ to read "’wholly, exclusively and necessarily”: that is the very wording of the Canadian Statute. ...

’ ’ Throughout the period mentioned there were three issued shares of Career Girl Store Limited (hereafter referred to as Career Girl) all of which were beneficially owned by Allied Business Supervisions Limited (hereafter referred to as Allied). ... But there was no question asking: ‘ ‘ Did beneficiaries of a trust ‘control’ or ‘have a controlling interest’ in the company?’’ ... In truth, the articles of association constitute a contract between the company and the shareholders which every shareholder is entitled to insist upon being carried out. ’ ’ That an article can restrict the right of a mere majority to bind the minority by an ordinary resolution appears from Quin & Axtens Ltd. et al. v. ...

Alpine Drywall & Decorating Ltd. v. Minister of National Revenue, [1966] CTC 359, 66 DTC 5263 CATTANACH, J. ... Alpine Drywall & Decorating Ltd. v. M.N.R., [1966] C.T.C. 359; Vineland Quarries & Crushed Stone Ltd. v. ... In view of the conclusion I reached in Vineland Quarries & Crushed Stone Limited v. ...

Joseph Simard & Cie, Ltee v. Minister of National Revenue, [1964] CTC 461, 64 DTC 5289 DUMOULIN, J. ... Simard & Cie Ltée, était une compagnie personnelle, l’entière propriété de Joseph Simard. ... André Piché, secrétaire de Foils Investment, en 1955 et antérieurement, spécifie que cette compagnie ‘‘.. est une ‘holding’ qui détient toutes les actions de Dominion Foils et que ne détient que ça dans son actif. ...

William $. Walker, [1951] CTC 334 HYNDMAN, D.J.:—These two appeals were heard together. ... Mallandaine, (1887) 18 Q.B.D. 276 at 277, Lord Denman said: "The words in 5 & 6 Vict. c. 35, s. 100, Sched. ... It will be noted that Lord Denman says ‘‘ ‘vocation’ is analogous to ‘calling.’ ”’ Other decisions which might be referred to are found in Gordon’s Digest, e.g., Trautwein v. ...

Campeau & Michael Petritz v. Minister of National Revenue, [1970] CTC 306, 70 DTC 6223 GIBSON, J. ... The relevant facts are as follows: The appellant Campeau was employed by and owned shares in two incorporated companies named Depco Metal Products Limited (herein called “Depco”) and Hercules Tool & Die Limited (herein called “Hercules”) and the appellant Petritz was employed by and owned shares in one only of the said incorporated companies, namely, Depco. ... London & West Riding Investments, Lid., [1967] 1 All E.R. 518 at 528; Littlewoods Mail Order Stores Ltd. v. ...