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James Richardson & Sons v. M.N.R., 84 DTC 6325, [1984] CTC 345, [1984] 1 S.C.R. 614-- summary under Section 231.2 Summary Under Tax Topics- Income Tax Act- Section 231.2 "S.231(3) is only available to the Minister to obtain information relevant to the tax liability of some specific person or group of persons if the tax liability of such person or persons is the subject of a genuine and serious inquiry. ...

Wampole & Co. Ltd., [1931] S.C.R. 494-- summary under Double Taxation/Deduction (Presumption Against) Summary Under Tax Topics- Statutory Interpretation- Double Taxation/Deduction (Presumption Against) no intention to impose sales tax twice on manufacturer S. 87(d) of the Special War Revenue Act, imposed tax on goods which were “for use by the manufacturer or producer and not for sale,” was found to apply to the distribution by a pharmaceutical manufacturer of drug samples to doctors, but for the fact that the samples had already been subject to tax in the hands of the manufacturer. ...

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) Major J. noted, with respect to a clause in a lease that gave the lessee the unilateral right to compel the lessor to sell helicopters to the lessee at their reasonable fair market value, that the giving of initial notice by the lessee 120 days prior to the expiry of the lease could not qualify as an "exercise" of the option (irrespective of how the giving of notice was labelled), given that the exercise of an option must lead to a binding contract of a purchase and sale. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Expressio Unius est Exclusio Alterius Summary Under Tax Topics- Statutory Interpretation- Expressio Unius est Exclusio Alterius reference to person implied exclusion of persons In finding that reference to control by a person did not include control by persons, Cartwright J. stated (pp. 1192-1193): "When section 127 by clause (b) provides that corporations controlled directly or indirectly by the same person shall be deemed not to deal with each other at arm's length it appears to me to negative the view that corporations are to be deemed not to deal with each other at arm's length when controlled not by the same person but by the same group of persons. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Subsection 33(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 33(2) In finding that reference to control by a person did not include control by persons, Cartwright J. stated (pp. 1192-1193): "When section 127 by clause (b) provides that corporations controlled directly or indirectly by the same person shall be deemed not to deal with each other at arm's length it appears to me to negative the view that corporations are to be deemed not to deal with each other at arm's length when controlled not by the same person but by the same group of persons. ...

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership the shares of a subsidiary of a corporation are not owned “indirectly” by the shareholders of that corporation Whether a corporation (the Western Company) was related to its two equal corporate shareholders (the Alberta Company and the Saskatchewan Company) under s.36(4)(b)(iii) of the 1948 Act turned, in part, on whether the related individuals owning all the shares of the Alberta Company and the Saskatchewan Company were to be considered as “owning] directly or indirectly” the shares of the Western Company. ...

Goodyear Tire & Rubber Co. of Canada Ltd. et al. v. T. Eaton Co. ...

Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545-- summary under Subsection 92(2) Summary Under Tax Topics- Other Legislation/Constitution- Constitution Act, 1867- Subsection 92(2) provincial tax styled as a direct "income tax" was in substance an ultra vires indirct tax on oil exports In order to divert to itself the increase in the price of oil that occurred after 1973, the Legislature of Saskatchewan enacted a "mineral income tax" approximately equal to 100% of the difference between the price received at the well-head and the price formerly received by the producers. ...

Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax Dickson, J. made a finding (at p. 477) in which the majority concurred (at p. 458) that a "mineral income tax" which effectively taxed 100% of the difference between the price received by oil producers at the well-head and the price they formerly received before the increase in oil prices following the 1973 energy crisis, was not an income tax: "The tax is not levied upon net income. ...

Wampole & Co. Ltd., [1931] S.C.R. 494-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) “use” includes providing free samples S. 87(d) of the Special War Revenue Act, imposed tax on goods which were “for use by the manufacturer or producer and not for sale,” was found to apply to the distribution by a pharmaceutical manufacturer of drug samples to doctors, but for the fact that the samples had already been subject to tax in the hands of the manufacturer. ...