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I don’t think the intent was to save the company in the technical — I mean in the words that you used them. ... He subsequently proved as a creditor in the company’s bankruptcy and received two dividends — one in 1959 for $6,119 and the other in 1961 for $3,200. ... See Stewart & Morrison Limited v MNR, [1972] CTC 73; 72 DTC 6049, in this Court. ...

The judgment of this Court in that case was delivered February 7th, 1933, and shortly thereafter Parliament amended the Special War Revenue Act by ch. 50, 1932-33, sec. 20, adding a provision (sec. 98) that where goods are sold at a price (that is, by the manufacturer or producer) "which in the judgment of the Minister" is [Page 180] less than "the fair price on which the tax should be imposed ", the Minister shall have the power to determine the fair price and the taxpayer shall pay the tax on the price so determined. ... It was held that in arriving at the amount of the income taxes to be paid by the Pioneer Laundry & Dry Cleaners, Ltd., the Minister had actually not exercised the discretion left to him by the Act as to depreciation, and the matter was referred back to him in order that that should be done. ... Solicitor for the respondent: Mulock, Milliken, Clark & Redman. [1] [1941] Ex. ...

To obtain these deductions Falconbridge must show that they come within Section 53(4) of the 1949 income tax amending Act, 1949 (Second Session), ¢. 25. ... J ULLBRIDGE There are four items of expenditure relating to those agreements: Depart Decision Item Item Period of Expenditure mental in Exche Decision quer Court I. $ 10,512.05 Prior to November 14, 1950, date of incorporation of Gullbridge Disallowed Allowed The Minister appeals the allowance of the first two items and Falconbridge appeals the disallowance of the second two. ... STANMORE Item XI. $15,063.71 This agreement is dated April 27, 1951, between Falconbridge, Stanmore Mining & Smelting Limited and a number of other companies and individuals. ...

McKay and $. M. Baird. The minutes of a meeting of the directors of the old company held on June 21 show that on that date Stuart resigned as president and director of the company and Sheldon, Jr., was appointed to both offices in his place, and Nicholson resigned as director and secretary, being replaced by Egoff. ... The Income Tax Act does not define the expression ‘‘ dealing at arm’s length’’, though Section 127(5) (b) provides that, for the purposes of the Act, corporations controlled directly or indirectly by the same person: “shall, without extending the meaning of the expression ‘to deal with each other at arm’s length’, be deemed not to deal with each other at arm’s length.’’ ...

Section 108, Part XIV, it should be observed, presupposes the existence of a tax or sum "payable under this Act," the existence, that is to say, of a legal duty, imposed by the statute upon the person from whom the "debt" is alleged to be "due" or the "right enforceable " to pay to the Crown the sum sued for. ... Solicitors for the respondent: Grossman, Holland & Co. [1] (1933) 47 B.C. ...

The only regulation to which we were referred is regulation 19 which reads in part as follows: 19. (1) The value of every annuity, term of years, life estate, income, or other estate and of every interest in expectancy, shall be determined, (ii) if the succession depends on life contingencies, on the basis of interest as aforesaid, together with the standard of mortality as defined in Table II below … [Page 605] In my opinion, the terms of this regulation are thus expressly limited, as is s. 34 itself, to the valuation of the interests mentioned which are included in the succession, the duty in respect of which is being determined. ... His figure of $55,000, he said, was on the basis of return of the principal within 13 ½ years with interest at 4 per cent. ...

The relevant subsection of the Income Tax Act and Section 693 of the Criminal Code provide as follows: * 136. (4) An information or complaint under the provisions of the Criminal Code relating to summary convictions, in respect of an offence under this Act, may be laid or made on or before a day 5 years from the time when the matter of the information or complaint arose or within one year from the day on which evidence, sufficient in the opinion of the Minister to justify a prosecution for the offence, came to his knowledge, and the Minister’s certificate as to the day on which such evidence came to his knowledge is conclusive evidence thereof. 693. (1) Except where otherwise provided by law, this Part applies to proceedings as defined in this Part. (2) No proceedings shall be instituted more than six months after the time when the subject matter of the proceedings arose.” ... Phillips, [1891] 2 Q.B. 267 at page 271: “Now a repeal by implication is only effected when the provisions of a later enactment are so inconsistent with or repugnant to the provisions of an earlier one, that the two cannot stand together, in which case the maxim, ‘ Leges posterior es contrarias abrogant’ (2 Inst. 685) applies. ...

Dans la présente loi, l’expression: (a) fabricant ou producteur comprend,— (ii) toute personne, firme ou corporation qui possède, détient, réclame ou emploie un brevet, un droit de propriété, un droit de vente ou autre droit à des marchandises en cours de fabrication, soit par elle, en son nom, soit pour d’autres ou en son nom par d’autres, que cette personne, firme ou corporation vende, distribue, consigne ou autrement aliène les marchandises ou non,” “... des marchandises en cours de fabrication’’ should be taken as the equivalent of ‘‘goods (which are) being manufactured’’. ... The sales tax is imposed by Section 80 of the Excise Tax Act in the following words: “30.(1) There shall be imposed, levied and collected a consumption or sales tax of eight per cent on the sale price of all goods (a) produced or manufactured in Canada (i) payable, in any case other than a case mentioned in subparagraph (11), by the producer or manufacturer at the time when the goods are delivered to the purchaser or at the time when the property in the goods passes, whichever is the earlier,.... ” Although, in this section, the reference is to the tax being payable by the producer or manufacturer’’ rather than to the manufacturer or producer’’ in Section 2, the meaning of each phrase is the same. ...

The following classes of tangible personal property are specifically exempted from the provisions of this Act: *** (m) Sales at a price of less than fifteen cents. ... Solicitors for the appellant: Guild, Yule, Lane & Collier, Vancouver. Solicitors for the respondent: Paine, Edmonds & Co., Vancouver. [1] Sub nom. ...

Thus, for any particular item: Income Profit = Sale Price- Purchase Cost. ... Thus for a business involved in sales: Gross Profit = Proceeds of Sale- [(Value of Inventory at beginning of year + Cost of Inventory acquisitions)- Value of Inventory at end of year.] ... See also: Whimster & Co. v. CIR (1925), 12 T.C. 813 (Ct. Sess., Scot.), at page 823 (per Lord Clyde); and BSC Footwear Ltd. v. ...