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Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280 Docket: 2017-2928(GST)G BETWEEN: DOW & DUGGAN LOG HOMES INTERNATIONAL (1993) LIMITED, and HER MAJESTY THE QUEEN, Respondent.   ... Factual background – Deposits and work-in-progress [59]   With respect to work-in-progress, Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Acts, 1867 to 1946, "shall apply to the Province of Newfoundland * * * except in so far as varied by these terms," the repeated references to the B.N.A. ... Act divides the entire legislative field between the Parliament of Canada and the legislatures of the provinces, or as it is stated by Lord Hobhouse: * * * an Act of Parliament which makes an elaborate distribution of the whole field of legislative authority between two legislative bodies * * * Bank of Toronto v. ... In so far as its powers were powers of regulation, they have passed to the Dominion Parliament * * * the disposal of property and the exercise of the power of regulation. ...

Paragraph 12 refers to — and I quote — Lou Lokash Limited received a benefit or advantage in the amount of $50,000 from Lou Lokash & Associates Limited which amount is included in computing the income of Lou Lokash Limited, a shareholder, pursuant to subsection 15.1 of the Income Tax Act. ... They had only the word of Lou Lokash that they held a proportionate interest in such a mortgage — indirectly through the corporation Lou Lokash & Associates, but they held nothing directly in the mortgage as such. ... What they had was simply their confidence in the organization “Lou Lokash & Associates” — in fact in Lou Lakash personally, if one would care to put it on that basis. ...

(Transcript: pages 63 & 64) Q. Do you recall when — now you said I think sometime in 1979 — the first of these leases was entered into sometime in 1979? ... Interest rates will be charged as follows: Trennd — operating — at the bank’s minimum lending rate (MLR) + 1 per cent — special — MLR+2 2 per cent Pioneer — capital — MLR + 11/2 per cent Allied — capital — MLR + 11/2 per cent — interim — MLR + 2 per cent Cal-Gas — capital — MLR + 11/2 per cent CIBC also advised that it would review this line of credit on or about September 30, 1981. ... The plaintiff still argues that the true purpose of the $1.7 million borrowing on a proper view of the transaction — truly the transactions — and the Court views them back to summer 1978 — was to provide a credit facility for Cal-Gas. ...

Stewart & Morrison Limited, [1970] CTC 431, [1970] DTC 6295 KERR, J. ... The so-called New York office was Stewart & Morrison Inc. a wholly owned subsidiary of the respondent. ... The letter states: In response to your request we are pleased to submit below a record of amounts received by Stewart & Morrison, Inc. from Stewart & Morrison Limited as capital contributions and loans payable. ...

& D. H. Holdings Limited v. Minister of National Revenue, [1986] 2 CTC 2364, 86 DTC 1730 Taylor, T.C.J. ... This amount was calculated by the Respondent as follows: Milk Quotas Other Assets Total Total Proceeds $1,600,000.00 $1,094,700.00 $2,694,700.00 Adjusted Cost Base 1,000,000.00 515,000.00 1,515,000.00 Excess $ 600,000.00 $ 579,700.00 $1,179,700.00 Section 14 — Proceeds (12) $ 300,000.00 $ 289,850.00 $ 589,850.00 Milk Quotas Other Assets Total Total Opening Balance Accumulative Eligible Capital $ 1,579.00 Nil $ 1,579.00 Revised Negative Accumulative Eligible Capital $ 298,421.00 $ 289,850.00_$_ 588,271.00 Deduct: Amount reported Nil $ 289,850.00 $ 289,850.00 Increase reassessment $ 298,421.00 Nil $ 298,421.00 (cc) the Appellant acquired shares of Robbinex Trading Corporation (hereinafter 'Robinex’) from its parent company’s shareholders for $700,000 on or about January 1, 1981. ... The butter might be stored on the premises of the appellant — at the option of the C.D.C. — but that in no way altered this elementary situation. ...

Ogulnik & Co. Ltd., [1928-34] CTC 274 TELLIER, C.J.—The following is the provision of the Special War Revenue Act, R.S.C. 1927, c. 179, sec. 86 on which the plaintiff relies:— " 1 86. ... This would be sufficient to dispose of the case, if the Minister of National Revenue had not, in the exercise of the power conferred upon him by sec. 95 of the said Special War Revenue Act, enacted a regulation which the defendant invoked, the text of which is as follows:— "‘(11) Merchant tailors, dressmakers, milliners and florists selling exclusively by retail to the consumer or user are classified as retailers and are not required to take out a Sales Tax License. ‘ " The terms ‘merchant tailor ‘ and ‘ dressmaker ‘ in this regulation means the ordinary merchant and the ordinary dressmaker who fits, makes and sells his goods to the order of the individual customer on the same premises upon which they are made and not through agents or chain of stores.’’ ... The following is the state of the total sales in bulk, and by retail for each one of the five years in question:— Year Retail Bulk 1924 $71,953.51 $ 65,000.11 1925 65,455.61 104,967.11 1926 • 72,149.93 125,692.72 1927 72,571.56 136,539.26 1928 69,164.42 169,328.83 $391,285.08 $601,528.03 As may be seen, the wholesale business exceeded that by retail considerably. ...

The names of four persons who, on January 24, 1967, resigned as officers and directors of Vineland and the positions which they held with Vineland at the time of their resignations were as follows: Benjamin Sauder — president and director Shirley Sauder — treasurer and director Samuel Taylor — vice-president and director E. ... Goodman & Carr. Mr. Franklyn E. Cappell of this firm had, however, written to Mr. ... Goodman & Carr. I intend to grant the present application and to hold Messrs. ...

& Sons Co. Ltd., [1970] S.C.R. 220 Supreme Court of Canada R. v. J.B. ... & Sons Co. Ltd. (by suggestion) formerly The John Bertram and Sons Co. ... Solicitors for the respondent: Rosenfeld, Schwartz & Brown, Toronto ...

& Co. Ltd. v. Minister of National Revenue, [1957] CTC 190 THURLOW, J. ... ‘ ‘ The way in which the Lord Justice Clerk applied the test is also of interest. ... " Unies you can get something worthwhile on the Drury Inlet timber, either on a lump sum or with a worthwhile deposit held so that it cannot be manipulated like the McNaughton one, we will let this timber stand hoping that prices will pick up in a reasonable period. ‘ ‘ Yours truly, • • GILLIES BROS. ...