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Counsel for the Minister was frank to concede that the transactions between Companies and Paper were real and did not constitute a “sham” within the definition of that word in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 519 where Lord Diplock said at 528:... it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...

In The Queen v Ken & Ray’s Collins Bay Supermarket Limited, [1975] CTC 504; 75 DTC 5346, Kerr, J decided that a somewhat similar management bonuses arrangement was contingent on the necessary funds being available. ...

As I see it, the payment toward the mortgage can only be an allowance for maintenance of those for whom maintenance was intended under the agreements — that is, the defendant at least initially, and any children living at home after July 1982 pending completion of their education. ...

The Queen, [...] that argument cannot be rejected. Indeed, in that decision, as I read it, the Court held that the word "distribution" in Class 2 is used in a very general sense that encompasses what the jargon of the natural gas industry refers to as the transmission and the distribution of gas. ...

Squibb & Sons Ltd. v. M.N.R., [1973] F.C. 162; [1973] C.T.C. 120, The Queen v. ...

., General Signal and Appliances Ltd. and Black & Decker Ltd. accounted for federal sales tax on small electrical appliances based on such determined values, which were requested by the above-mentioned companies and were authorized by Excise. ...

.* 256 common Adrien Allard * Chipik Investment Ltd. and Allard Ventures Ltd. became shareholders in July 1976. ...

London & West Riding Investments Ltd., [1967] 1 All E.R. 518, [1967] 2 Q.B. 786 (C.A.) at page 528 (Q.B. 802):.... which are intended by them to give to third parties or to the Court the appearance of creating between the parties legal rights and obligations different from the actual legal rights and obligations (if any) which the parties intend to create. ...

The Statute The relevant provisions of the Income Tax Act are found in Part I, Division I — Returns, Assessments, Payment and Appeals. ...

Indian Head School Division 19 ® [30] in ascertaining the existence and extent of the duty of fairness owed to those affected by a decision, a strong argument can be made in this instance that the Applicant was entitled to state its views before the Minister could hold that its imports were no longer eligible for remission. ...