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For instance, the following is to be found in subs. 3(e) of s. 11 of the Income Tax Act: … there may be deducted … an amount equal to the lesser of (a) … (b) the amount determined under paragraph (a) less the amount, if any … It must now be observed that s. 702 (1) of the regulations in force at the material time defines to a certain extent the mining taxes that may be deducted in computing income. ... Spruce Falls Power & Paper Co. Ltd. [5] on which both parties [Page 530] have relied. ... Solicitors for the appellant: Fasken & Calvin, Toronto. Solicitor for the respondent: D.S. ...

Notice of assessment — Alteration without notice by Court of Revision — Liability of ratepayer. ... Then at the bottom — “ Take notice that you are assessed as above specified for the year 18 — under the statutes. ... Sous l ’ opération de ce dernier statut, une question semblable à celle dont il s ’ agit présentement s ’ est élevée dans la cause de “ The municipality of the Township of London vs. ...

., 1927, c. 1, which was in force long before the enactment of the Income War Tax Act, 1917, and it provides that ‘ " Definitions or rules of interpretation contained in any Act shall, unless the contrary intention appears, apply to the construction of the sections of the Act which contain those definitions or rules of interpretation, as well as to the other provisions of the Act.” ... It is by the agreement, for the lack of an apt definition, termed a " " royalty ’ ’; but, whether or not it may appropriately be named a royalty or an annuity, the statute does not, in terms, charge either royalties or annuities, as such; and here the appellant has converted the land, which is capital, into’ money, shares and ten per cent of the stipulated minerals which the company may win. ... & N. 769. Or a man may sell his property for an annuity. In that case the Income Tax Act applies. ...

    $1,142.00 1946 ……………………………………………………………….      1,620.00 1947 ……………………………………………………………….      1,240.00 1948 ……………………………………………………………….      1,575.00 1949 ………………………………………………………………..           nil 1950 ……………………………….……………………………….      2,600.00 1951 ………………………………………………………………..      1,350.00 1952 ………………………………….…………………………….      1,080.00 All of the topsoil taken in these years and in respect of which the said amounts were received by the appellant, was taken from the thirty-seven acre parcel of the appellant's property situated to the north of the Canadian Pacific Railway right-of-way. ... Solicitors for the appellant: McCarthy & McCarthy, Toronto. Solicitor for the respondent: E. ...

By section 3, income is defined; and income of the kind we are considering, profits of a business, is ‘‘ profits * * * received by a person * * * from any trade, manufacture or business * * * whether derived from sources within Saskatchewan or elsewhere. ’ ’ It is clear, I think, that the effect of the words "‘net profit or gain arising from the business of such person in Saskatchewan” in section 21a is, for the purpose of that section, to delete from the definition of income in section 3 the words "‘or elsewhere. ’ ’ This view of section 21a is fortified by the language of other provisions. In section 4 it is enacted:— The following incomes shall not be liable to taxation hereunder: *** (m) profits earned by a corporation or joint stock company * * * in that part of its business carried on at a branch or agency outside of Saskatchewan. ... So far as relates to these two processes, therefore, their Lordships think that the income was earned and arising and accruing in New South Wales. * * * This point was, if possible, more plainly brought out in Tindal’s case (1897), 18 N.S.W.L.R. 378. * * * The question in that case, as here, should have been what income was arising or accruing to Tindal from the business operations carried on by him in the Colony. ...

There were circumstances, in the consideration of these two cases, which could be relied on in one case and not in the other. * * * To decide whether this Court has jurisdiction we must therefore look at the amounts in the two actions. ... Nelson & Fort Sheppard Ry. Co. (8 West. W.R. 99), Glen Falls Ins. ... Hilaire, Boucher, DeBlois, Parent, Proulx & Leclerc, Quebec. Solicitors for the defendants, respondents: Joli-Coeur, Joli-Coeur & Mathieu, Québec ...

By section 1 (b) of the Act, it is provided that ‘‘ ‘security’ shall include (i) any share of capital stock or debenture stock and any bond or debenture issued by any * * * company.” ... For the appellant, it is contended that there was no “change of ownership ‘ ‘ of any " " issued ‘ ‘ shares at all and that section 2, by reason of the definition of “security,” applies only to a change of ownership of shares already issued. ... In the case at bar then, the Crown must show a transfer involving a change of ownership of a "" security’ ‘ within the meaning of the Security Transfer Tax Act. ...

His Lordship added: "After all, the Supreme Court Act is concerned not with the authority which is the source of the ‘ criminal ’ law under which the proceedings are taken, but with the proceedings themselves. ’ We have, therefore, to inquire whether the proceeding against the respondent was in its character civil or was criminal in the sense indicated. ... Tyler & The International Commercial Coy., Ltd. [1891] 2 Q.B. 588. ... Happily, in my view, it is unnecessary to discuss the scope of such words as ‘ ‘ crime ‘ ‘ and ‘ i criminal cause ‘ ‘ in the abstract; an enticing subject, perhaps, for lozomachy, but, in my view of the effect of sec. 36, of little importance here. ...

Subsection 40 of Section 2 of the Insurance Act reads: — “MUTUAL INSURANCE. ... Subsection 1 of Section 3 of the Income War Tax Act, in so far as it affects the present matter, reads:— ‘ ‘ For the purposes of this Act 1 income ’ means the annual net profit or gain.... being profits from a trade or commercial or financial or other business or calling.... and shall include the interest, dividends or profits directly or indirectly received from money and interest upon any security or without security or from stocks or from any other investment, and whether such gains or profits are divided or distributed or not. ’ ’ The question is whether the surplus resulting from the amounts received from premiums paid in cash at the time the insurance is effected and from assessments being in excess of that required for the company’s operations is a profit or gain. ... Is it possible to say that this is an association for the purpose of profit, or that it has made any profit “.? ...

., 2016 SCC 56, [2016] 2 S.C.R. 720       SUPREME COURT OF CANADA   Citation: Canada (Attorney General) v. ... Respondents     Coram: McLachlin C.J. and Abella, Cromwell, Moldaver, Karakatsanis, Wagner, Gascon, Côté and Brown JJ.   ... Commercial law — Corporations — Taxation — Whether rectification of contract amounts to retroactive tax planning.                     ...