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I set out the letter of commitment which was written to the special counsel retained by the tax department; it is as follows: Mr C Gordon Dilts, Barrister & Solicitor, 503 Electric Railway Chambers, WINNIPEG, Manitoba. ...

En cela je suis d’accord avec le procureur des appelants qui écrit dans son mémoire: Section I — La première question qui se pose est celle de la juridiction de la division de première instance de la Cour Fédérale à supposer même que les appelants auraient raison de prétendre que le certificat (pièce P-2) constitue un faux et un abus de pouvoir d’une part et que l’article 244(4) ou bien ne s’applique pas vu la Déclaration canadienne des droits de 1960 ou doit être interprété comme limitant la portée des mots “preuve concluante” au tribunal de premiere instance devant lequel les appelants sont accusés, soit à la Cour des Sessions de la Paix. ...

Mallandaine [9], where it was held that persons receiving profits from betting systematically carried on by them throughout the year, are chargeable with income tax on such profits in respect of a "vocation" under 5 & 6 Vict., ch. 35 (the Imperial Income Tax Act), Sched. ...

Moreover, in the latter case, Pigeon, J said at page 882 [267, 6201]: “Mining itself is complete by the production and hoisting of the ore ‘...” ...

.: — 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. ...

  [1] [1977] C.A. 96, (1977), 1 C.R. (3d) 58. [2] [1976] C.S. 704. [3] [1978] C.A. 103, summary only. [4] [1975] 2 S.C.R. 160. [5] (1977), 36 C.C.C. (2d) 206. [6] Judgment delivered on October 17, 1978. ...

Relevant Staturory Provisions Income Tax Act, S.C. 1970-71-72, c. 63 (applicable to taxation years 1985 and 1986) 18.(1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (b) an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by this Part; 20.(1) Notwithstanding paragraphs 18(l)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (¢) an amount paid in the year or payable in respect of the year (depending upon the method regularly followed by the taxpayer in computing his income), pursuant to a legal obligation to pay interest on (i) borrowed money used for the purpose of earning income from a business or property (other than borrowed money used to acquire property the income from which would be exempt or to acquire a life insurance policy), 38. ...

Hays v Pacific Mail SS Co, 17 How 596; St Louis v Ferry Co, 11 Wall 423; Morgan v Parham, 16 Wall 471; cf Ayre & Lord Tie Co v Kentucky, 202 US 409. ...

On general principles then, the tax imposed by section 6A qualifies as a direct tax; see Canadian Industrial Gas & Oil Ltd v The Government of Saskatchewan, [1978] 2 S.C.R. 545. ...

In each Province the Legislature may exclusively make Laws in relation to Matters coming within the Classes of Subject next hereinafter enumerated; that is to say, — 14. ...