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., c/o Ryan, Graser & Smith, P.O. Box 38, Fredericton, N.B. E3B 4Y2. ... (signature) John (?) Church Signature of an authorized signing officer of the Corporation Secretary Position or Rank of Officer Date July 21 1979 (Appeal Book, at page 14). ...

See also at 245 where IOGC supported in its submission to the Minister the Manager's right to make decisions and rules in a retroactive manner. [11] For a definition of the word "retrospectivity", see [1977] 1 S.C.R. 271 "> Gustavson Drilling (1964) Ltd. ... [Je souligne] [14] The Attorney General of Alberta and The Minister of Lands and Mines of Alberta and Huggard Assets Limited and The Attorney General of Canada, [1951] S.C.R. 427 "> [1951] S.C.R. 427 at 437-41: revised on other grounds [1953] A.C. 420 (P.C). [15] A.B. pp. 81 and 120. [16] A.B. at 169. [17] A.B. at 171. ...

.: — This appeal is taken as to two paragraphs relating to costs in an interlocutory order by the Tax Court joining one Helga Georg as a party to an appeal brought by the respondent against the appellant. ... We do not regard the failure of the counsel for the respondent to request solicitor/client costs as alone fatal to the decision to award them, since in our view courts should have discretion to impose them on their own motion where warranted — but only after alerting counsel that such costs are under consideration and allowing the opportunity for presentation of both sides of the argument. ...

doing business, the appellant has had a dispute with the office of Revenue Canada, Customs & Excise, with respect to its liability for the payment of sales taxes on the septic tanks it was manufacturing. ... The “transitional” provision enacted in 1985 will be in force until it has been repealed—which is not the case—or until it has become obsolete (see subsection 2(2) of the Interpretation Act, R.S.C. 1985, c. 1-21) — which will not be the case until all applications filed before the coming into force of the 1985 Act have been dealt with. ...

.: — This is an appeal against a judgment of Addy, J. of the Trial Division of this Court whereby, upon motion made by the defendant, Her Majesty the Queen, pursuant to rule 419(1)(a) [1] of the Federal Court Rules, the action herein was dismissed on the ground that the statement of claim disclosed no reasonable cause of action. ... No addition to the statement of claim could alter the real nature of the action and this is why, be it said incidentally, that I would now deny the application for leave to amend made orally by counsel for the applicant in the course of the hearing — and then taken under advisement. 2. ...

— because it is an objection, they say, which is not in any way within the scope of section 222 of the Income Tax Act and has nothing to do with the debt being recovered. ... In my opinion, a finding by a court that the contract on which the third party relies to challenge the legitimacy of the seizure, or to argue that it has nothing to pay, is a sham, or, though real, cannot be set up against the garnisher — which as I mentioned is the purpose of the Paulian action — is still a decision directly connected with compulsory execution of the judgment. ...

In September 1984 the appellant was contacted by Boots & Coots, a well control company based in Houston, Texas, with respect to an underground blowout in an exploratory gas well being drilled by Mobil Oil Canada Ltd (“Mobil”) off the coast of Nova Scotia. ... Interpreting the 1942 Convention The basic principles to be applied in interpreting the 1942 Convention or any bilateral tax treaty are those found in articles 31 & 32 of the Vienna Convention on the Law of Treaties. ... Canada is a member of the Organization for Economic Co-operation & Development (“OECD”) which adopted a Model Tax Convention on Income & Capital (the “OECD Convention”) in 1977. ...

On this interpretation, subsection (7) could have application to taxpayers directly involved in contesting departmental interpretations before the Tariff Board or a Court or to those affected by an authoritative re-interpretation — this third group could include all taxpayers. ... A taxpayer who pays his taxes in good faith and under the general compulsion of the law should not be penalized for not challenging his Government’s right to the tax at every stage — annually, as recommended before us by counsel for the respondent. ... It provides that costs shall not be awarded — “unless the Court, in its discretion, for special reason, so orders” Since no special reasons were advanced, and none appear from the record, I would make no order respecting costs. ...

Finally, the learned judge followed the decision of this Court in Johnson & Johnson Inc. v. ... This Court was faced with a similar issue in Johnson & Johnson Inc. v. ... Sanford & Brooks Co., 282 U.S. 359, 365 (1931). Nevertheless, strict adherence to an annual accounting system would create transactional inequities. ...

Shofar Investment Corp. [4] when, at page 5849 of the report, he approved of what Jackett, C.J. had said on the appeal in in the following excerpts from his judgment: — What we are concerned with here is "gross profit”. ... In fact, "inventory" then and in 1978 was defined in similar terms, viz: — ''inventory" means a description of property the cost or value of which is relevant in computing a taxpayer's income from a business for a taxation year. ... It reads as follows: — 9.(1) Subject to this Part, a taxpayer's income for a taxation year from a business or property is his profit therefrom for the year. ...