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Joseph Simard & Cie, Ltee v. Minister of National Revenue, [1964] CTC 461, 64 DTC 5289 DUMOULIN, J. ... Simard & Cie Ltée, était une compagnie personnelle, l’entière propriété de Joseph Simard. ... André Piché, secrétaire de Foils Investment, en 1955 et antérieurement, spécifie que cette compagnie ‘‘.. est une ‘holding’ qui détient toutes les actions de Dominion Foils et que ne détient que ça dans son actif. ...

Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221 ABBOTT, J. ... This raises two questions, namely: (1) Whether income which the appellant earned in Canada in its character as a general agent or stevedore is "" income.... earned in Canada from the operation of a ship’’ or "‘profits which.. ...

Hudson Bay Mining & Smelting Co. v. R., 99 DTC 5269, [1999] 3 CTC 76 (FCA) Strayer J.A.: This is an appeal from a judgment of the Tax Court of Canada. ... Thomas Summerson & Sons Ltd. [1] and R. v. Immobilière Canada Ltd. [2] are distinguishable in that they each involved the purchase of a debt instrument by someone other than the debtor under that instrument. ...

Coopers & Lybrand Limited, Agent for Mercantile Bank of Canada and Receiver and Manager of Venus Electric Limited, [1980] CTC 406, 80 DTC 6323 Urie, J:—The respondent seeks to have this Court reconsider its judgment herein on two grounds: (a) that the sum referred to on pages 15 and 16 of the reasons for judgment in respect of the amount which the respondent had available to it to pay on account of wages was $190,270 rather than $196,207.01 as shown therein; (it has been conceded by the appellant that the latter figure is incorrect and the proper figure for inclusion in the reasons is $190,270 and the reasons for judgment will be so amended), and (b) that the pronouncement as it relates to costs does not agree with the reasons. ... While the applicant, Coopers & Lybrand Limited, quite properly brought to the Court’s attention the error in the figures shown on pages 15 and 16 of the reasons, correction of such error could have been accomplished quite simply by applying to the Court to effect the necessary correction without combining that application with the application for reconsideration of the Court’s disposition of costs. ...

Rudelier Ranches & Livestock Co. Ltd. v. The Queen, 89 DTC 5180, [1989] 1 CTC 417 (FCTD) Dubé, J. ... Nelson Rudelier is also involved in the real estate business and is the sole owner of a holding company, the defendant Rudelier Ranches & Livestock Company Ltd., incorporated in 1973. ... RUDELIER RANCHES & LIVESTOCK COMPANY LTD. (plaintiff) 100% owned by Nelson Rudelier Date of Purchase Date of Sale (1) 540 Helmcken St. ...

Deputy Minister of National Revenue for Customs & Excise v. Steel Company of Canada Limited, [1983] CTC 258, 83 DTC 5301 Heald, J:—This is an appeal on a question of law pursuant to leave granted by this Court, from a declaration of the Tariff Board dated January 13, 1982. ... Subsection 1(a) of Part XIII uses the words “... imported by manufacturers or producers for use by them...” ... The decision of the Supreme Court of Canada in the case of Irving Oil Ltd v The Provincial Secretary of the Province of New Brunswick [1980] 1 S.C.R. 787, is authority for the view that “... the requirement of direct use is fulfilled irrespective of the percentage of use that may be ascribed to the process of manufacture as opposed to other processes such as storage and distribution.” [5] Accordingly, it is my conclusion that while the Tariff Board did not err in law in deciding that the columns in issue are parts of the cranes and therefore not subject to the sales or consumption tax imposed by section 27 of the Excise Tax Act, it erred in declaring that only the portions of the columns designed to support the overhead cranes are exempt from the sales tax. ...

Ken & Ray’s Collins Bay Supermarket Limited v. Minister of National Revenue, [1974] CTC 2267 Judge K A Flanigan (orally: March 6, 1974):—This is an appeal by Ken & Ray’s Collins Bay Supermarket Limited against the reassessment of the Minister of National Revenue for the 1969 and 1970 taxation years. ... The evidence in this case has been given by Mr Partridge, an auditor with the firm of Thorne Gunn & Co, the auditors for the appellant company, and in his view sound accounting business practices were followed in setting up a new form of bookkeeping system when they accepted this company as one of their accounts. ...

Campeau & Michael Petritz v. Minister of National Revenue, [1970] CTC 306, 70 DTC 6223 GIBSON, J. ... The relevant facts are as follows: The appellant Campeau was employed by and owned shares in two incorporated companies named Depco Metal Products Limited (herein called “Depco”) and Hercules Tool & Die Limited (herein called “Hercules”) and the appellant Petritz was employed by and owned shares in one only of the said incorporated companies, namely, Depco. ... London & West Riding Investments, Lid., [1967] 1 All E.R. 518 at 528; Littlewoods Mail Order Stores Ltd. v. ...

Southco Holdings & Management Ltd. v. Minister of National Revenue, [1975] C.T.C. 2205, 75 D.T.C. 162 Roland St-Onge (orally: January 9, 1975): 1 This appeal is from a reassessment dated November 21, 1972, with respect to the 1969 taxation year. ... Chamberlain (HM Inspector of Taxes), 45 TC 92at 106, and I read: Therefore, the learned Judge held, as I understand it, that because it was a hedge against devaluation it was not a trading adventure; and, notwithstanding the other findings of the Commissioners, he held that, if they had rightly appreciated the facts, that was the conclusion to which (...) they must have come. ... And then, the learned judge of the Exchequer Court laid down the following positive guides at page 214 [1139] stating that a transaction is “an adventure in the nature of trade” (1) “... if a person deals with the commodity purchased by him in the same way as a dealer in it would ordinarily do”, and (2) if “the nature and quantity of the subject matter of the transaction may... exclude the possibility that its sale was the realization of an investment...”. 23 In the present appeals it cannot be said that the gold was acquired as an investment. ...

Plaskett & Associates Limited v. Minister of National Revenue, 91 DTC 162, [1991] 1 CTC 2162 (TCC) Sobier,T.CJ. ... In particular, she referred to In re Stuart & Sutterby (1929), 2 C.B.R. 1 (Ont. ... This decision was appealed to the Supreme Court of Ontario and reported as In re Stuart & Sutterby (1930), 2 C.B.R. 279. ...