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.: — Dissension reigned in 1979 among the four shareholders of Les Industries S.L.M. ... According to the Minister, S.L.M. artificially or unduly created a loss of $ 1,000,000. ...

.: — 1. Issue This case raises an important and controversial issue concerning the interpretation of ss. 67(1)(b) and 91 of the Bankruptcy and Insolvency Act, R.S.C., 1985, c. ... Ramgotra transferred the funds from his two RRSPs into his exempt RRIF when he was solvent, and not for the purpose of defeating his creditors, one might well wonder how the bank could get around the exempt status of the RRIF — a status which, on its face, constitutes an absolute bar to the bank’s claim. ...

I use the term “ significantly profitable” because it appears from the Morrissey decision that the quantum of expected profit cannot be ignored and I take this to mean that one must have regard to the relative amounts expected to be earned from farming and from other sources. Unless the amount reasonably expected to be earned from farming is substantial in relation to other sources of income then farming will at best be regarded as a “ sideline business” to which the restriction on losses will apply in accordance with subsection 31(1). ...

Collier & Sons Ltd. (hereinafter called Collier) for the early part of 1982 and the latter part of 1985, and with Grolier Ltd. ... Block Research & Development (1981) Corporation v. M.N.R., [1987] 1 C.T.C. 253, 87 D.T.C. 5137 and my own decision in the case of Gibbs v. ...

The penalty assessment in each case was under subsection 163(2) and was imposed on each of them as a person who ”... knowingly... has made... a false statement... in a return. ... R., [1988] 6 W.W.R. 470 (Sask.Q.B.); Re Panarctic Oils Limited and the Queen(1982), 69 C.C.C. (2d) 393 (N.W.T.S.C.); 141 D.L.R. (3d) 138; and Matheson & McMillan v. ... & P.E.I. R. 189 (P.E.I.S.C.); 178 A.P.R. 189. 8. The fact that a corporation could not, because of its very nature, avail itself of some of the rights and freedoms confirmed or-conferred by the Charter, such as a right not to be a witness, or a right to liberty or to freedom of conscience, does not mean that other rights or freedoms which could be exercised by corporations should not be considered to have been conferred or confirmed for them. ...

Nomad Sand & Gravel Ltd., [1991] 1 C.T.C. 60, 91 D.T.C. 5032 (F.C.A.) do not apply. ... In Nomad Sand & Gravel Ltd., supra, the nature of the taxpayer's business did not give the taxpayer any on-going connection with its customers that would have allowed the taxpayer to demonstrate it had to provide future services. ... At page 318 (D.T.C. 6164) of his judgment, Décary, J. stated: The question is whether the debts at issue were in fact acquired ”... for the purpose of gaining or producing income from a business or property....” ...

In February 1976 a senior officer of the Life Insurance Division of the Department of Insurance wrote to the Society about its practice in respect to financing its fraternal activities and advised in part "... it would be appropriate for the society to establish a separate and distinct fraternal fund", a practice said by the writer to be contemplated by the Canadian and British Insurance Companies Act, since it appeared from the Society's report that it had the “intent... to accumulate a substantial fund for fraternal purposes”. ... The reason for this was that the closing of our 1978 books was delayed when our tax advisors, Clarkson, Gordon & Co., surprised us with the news that Income Tax would not be payable from 1978 onward. ... I have requested that a tax specialist from Clarkson, Gordon & Co. be present at our meeting to explain this rather complicated procedure to the Board this morning. ...

Zhelka, [1967] 2 O.R. 565, 64 D.L.R. (2d) 457; Smith, Stone & Knight Ltd. v. ... Additionally, in Smith, Stone & Knight Ltd. v. Birmingham Corp., [1939] 4 All E.R. 116 (K.B.), Atkinson J. came to the conclusion that a parent company could sue the persons responsible for damage caused to one of its subsidiaries. ... At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles: "... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act and the intention of Parliament". ...

Support is found for this view, in the well-known passage from the judgment of Lord Diplock in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 518 at 528, reading as follows: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd and the defendants were a “sham”, it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...

There were 64,000 issued and outstanding common shares without par value of Amherst Quarries (1969) Limited, held as follows: $ H.M. ...