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In 1952, Parliament eliminated from the Income Tax Act the rule in Section 13 (Section 10 of the Income War Tax Act) whereby the deduction of losses incurred in accessory business ventures was prohibited by providing that a taxpayer’s income “ shall be deemed to be not less than his income for the year from his chief source of income’’, and in 1958 Section 27(1) (e) was amended to provide for business losses being carried back or forward against income from any business instead of income from the same business only. ...

  [1] [1968] 2 Ex. C.R. 347, [1968] C.T.C. 233, 68 D.T.C. 5164. [2] [1968] 2 Ex. ...

Solicitors for the appellants: Howard, Cate, Ogilvy, Bishop, Cope, Porteous & Hansard, Montreal. ...

. ^86(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, payable by the producer or manufacturer at the time of the delivery of such goods to the purchaser thereof. ...

The doctrine laid down in Salomon v Salomon & Co, Ltd ([1897] AC 22; [1895-99] All ER Rep 33) has to be watched very carefully. ... This “sue for and recover” rule was followed in Re J Bibby & Sons, Ltd Pensions Trust Deed, Davies v IRC, [1952] 2 All ER 483. ... The principle of Salomon v Salomon & Co Ltd, supra, is still very much part of our law and in general the courts have rigidly applied it. ...

., summarized, [1990] 1 C.T.C. 84, 90 D.T.C. 6040 at page 86 (D.T.C. 6041), the respondents contended that the search and seizure provisions in section 231.3 were invalid because: (1) subsection 231.3(3) allows no discretion to a judge to guard against abusive searches and seizures — it requires a judge to issue a warrant if satisfied that there are reasonable grounds to believe that an offence has been committed and that evidence of that offence is likely to be found in certain premises; (2) subsection 231.3(5) allows wholesale searches and seizures, without adequate authorization, and therefore does not meet the requirements of a constitutionally valid search and seizure power, as set out in Hunter v. ... Bearing all this in mind, I conclude that subsection 231.3(3), by using the words ” shall issue”, denies the issuing judge the discretion to refuse to issue a warrant where in all the circumstances a search or seizure would be unreasonable. ... Rather, it meets the “ credibly based probability” standard required by section 8. ...

Subsequently, in 1941, the respondent, in determining the net income of the appellant for income tax purposes, ' for the year 1938, added a sum of $10,955.70, being $21.15 in respect of each of the original 518 shares of stock held by the appellant. ... With respect to section 16, it may be questioned whether the language "reduces … any class of the capital stock or shares thereof" contemplates a reduction in the par value of the shares outstanding. ... Solicitors for the appellant: Montgomery, McMichael, Common, Howard, Forsyth & Ker. ...

(b) ”... for the purpose...." It is not necessary to show that income actually resulted from the particular outlay or expenditure itself. ... (c) ”... gaining or producing income...." The word “income” refers to income after deductions as computed under Division B of the Income Tax Act. ...

XV (1) of the Convention, which reads: “ (1) As far as may be in accordance with the provisions of The Income Tax Act, Canada agrees to allow as a deduction from the Dominion income and excess profits taxes on any income which was derived from sources within the United States of America and was there taxed, the appropriate amount of such taxes paid to the United States of America.’’ ...

It is in this sense he was understood by the learned trial Judge, who, on this footing, puts the issue as follows: “... the sole question to be determined is whether or not there was a sale of the goods by the company to the retailers.?? ...