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There were 9,000 common shares issued, each carrying one vote per share, and held as follows: 1/3 by Ardwell Holdings Limited — 1,667 1/3 by Bradford Investments Limited — 1,666 1/9 by Doric Developments Limited — 556 1/9 by Loring Developments Limited — 556 1/9 by Adair Developments Limited — 555 Total 5,000 The shares in 42 other companies, referred to as the ‘‘Okun group”, were also held by these five corporations, except that El Cindad Limited frequently replaced Loring. ... Estate tax — Federal — Estate Tax Act, S.C. 1958, c. 29 — Section 7(1)(d)—Gifts and bequests to charitable organization—Gifts to trust —Whether a “trust” an “organization”—Possibility of unnamed beneficiaries — Whether gifts “absolute and indefeasible” — Meaning of “charitable”. ... The appellant in argument, submitted that “The Harshman Foundation ’ ’ was not an inter vivos or testamentary trust in the same way as was held in M.N.R. v. ...

[Page 48] (2) For the purpose of paragraph (a) of subsection (1) of section 40 of the Act, the following classes of corporations are prescribed: (a) corporations that are taxable under the provisions of section 3 of the Quebec Corporation Tax Act and that are not taxable under the provisions of section 6 of the Quebec Corporation Tax Act, and * * * 401. ... Solicitors for the appellant: Miller, Thomson, Hicks, Sedgewick, Lewis & Healy, Toronto. ...

Prior to August 19, 1964 the respondent and Messrs Robert A Steele and Gordon Symon were employed by J K Campbell & Associates Limited, hereinafter referred to as “Campbell Limited’, a company carrying on business as a roofing and heating contractor, in the four western provinces, with its head office in Edmonton. ... The auditor ascertained that 15% of the net annual profit before taxes of Campbell Limited’s consolidated operations in all cities was: 1965 — $ 37,745 1966 — 119,710 Out of the latter sum of $119,710, paid to Independent, a portion was distributed by Independent to the respondent, Steele and Symon as a bonus. ... The Minister in assessing the respondent included in his income for: 1965 — $12,581.67 1966 — 15,403.33 which amounts represented a one-third portion of the moneys paid by Campbell Limited to Independent which had not been distributed by Independent and which had not been included in his income for his 1965 and 1966 taxation years. ...

Smith, epitomized the crucial inquiry in a sentence — “Where could the shares be effectually dealt with?” The circumstances relied upon by the appellants which show the predilection of the members of the plaintiff company for transacting its business in Buffalo — so far as they might — have, in their Lordships’ opinion, no material weight. ... I am accordingly of opinion that the words ‘‘... if any register of transfers or place of transfer is maintained by the coporation in that province...’’ as they are used in Section 9(8)(d)(i) of the Estate Tax Act must be construed as meaning ‘ ‘ maintained ’ in accordance with the requirements of the statute under which the company in question was incorporated and that in the present case this must mean in the Province of Saskatchewan. ...

. * * * (7) For the purposes of this section and section two hundred and seven of this Act, “Territorial waters of Canada,” shall mean the waters forming part of the territory of the Dominion of Canada and the waters adjacent to the Dominion within three marine miles thereof, in the case of any vessel, and within twelve marine miles thereof, in the case of any vessel registered in Canada. By s. 207, as enacted by c. 16 of 1928, it is provided that If upon the examination by any officer of the cargo of any vessel hovering in territorial waters of Canada, any dutiable goods or any goods the importation of which into Canada is prohibited are found on board, such vessel with her apparel, rigging, tackle, furniture, stores and cargo shall be seized and forfeited * * *. ... Solicitors for the respondent: Henry, Stewart, Smith & McCleave. [1] (1930) 2 M.P.R. 350. 1 (1930) 2 M.P.R. 350. [2] (1930) 2 M.P.R. 350. 2 (1930) 2 M.P.R. 350. [3] [1906] A.C. 542. [4] [1912] A.C. 820, at 826. 3 [1906] A.C. 542. [5] [1906] A.C. 542. [6] [1926] A.C. 482. [7] [1926] A.C. 482, at 492. [8] (1930) 2 M.P.R. 350. 8 (1930) 2 M.P.R. 350. [9] [1925] A.C. 396, at p. 412. [10] 1878) 3 App. ...

After reference to portions of [Page 1047] The National Energy Program 1980, the stated goals of the tax and its apparent impact, the Court held the tax to be supported only by s. 91(3)   of the British North America Act, 1867  ,     30‑31 Vict., c. 3  , “The raising of Money by any Mode or System of Taxation”. ... The immunity would be illusory since, by the simple device of framing a tax as “ in personam ” rather than “ in rem ” one level of government could with impunity tax away the fruits of property owned by the other. ... Robertson (Fenerty, Robertson, Fraser & Hatch), Calgary.   ...

That expression means that portion of the company’s profits in excess of the " 4 standard profits’’. ... From the courteous reception we received we did not think it right to ask them how they were dealing with it. ‘ ‘ The duty of the Minister was to have the standard profits computed under the appropriate subsection of section 5. ... There was no question in that case of succession duties; but the notes of the present Chief Justice of Canada (Rinfret, J., as he then was) contain a lucid and helpful commentary on articles 981(a) to 981 (n) of the Civil Code, which are found under the caption " " Of Trusts ‘ ‘ and which obviously apply to all the Deeds concerned in the present case. ...

Opposite this last entry but under column 6, which is headed "" Occupation ”, appear the words ‘‘mining rights’’. ... By that time the Revised Statutes of Ontario 1937 were in force wherein the Assessment Act appears as ¢, 272. ... (k), (m), (n) and (o) of s. 1 of the Mining Act, R.S.O. 1927, ce. 45 (now R.S.O. 1937, ¢. 47, s. 1, cis. ...

In the Agreement for Leases dated July 7, 1944, made between the appellant and Leaseholds, the appellant granted to the former company: (€.. the sole and exclusive right to acquire a lease and/or leases of the said minerals in the form and upon the terms and conditions included in the draft lease attached hereto as Schedule ‘B’, and subject to the terms and conditions hereinafter set forth. ... Under our Lease with you, you are entitled to a 10 % royalty, but under the Imperial Option the royalty reserved graduates from 3% to 7 7%, depending on the year of purchase, and you hereby grant us the exclusive option of purchasing from time to time up to 7 % of your royalty on the following basis: It is to be noted that this letter states that under Leasehold’s lease Minerals was entitled to a ten per cent royalty but there was, in respect to these lands, no such lease and no such liability. ... On the first 10,000 acres-.— $2.63 for each 1% purchased. second ‘' 2.10 for each 1% purchased. “ third =‘ 6 1.58 for each 1% purchased. “ “ balance of acreage — 1.05 for each 1% purchased.” ...

The settled jurisprudence of the province of Ontario in relation to the words “the preferential lien of the landlord for rent” was stated by the late Chancellor Boyd in Re Fashion Shop Co. [3]: The phrase “the preferential lien of the landlord for rent” means * * * that the landlord has a statutory lien upon goods available for distress, independent of actual distress or possession, for the amount of the rent as limited by the section. ... Toronto Savings & Loan Co. [5] followed the Lazier decision (2), as did also the case of Re D.S. ... (Landlord): McMaster, Montgomery, Fleury & Co. Solicitors for the Workmen’s Compensation Board: Spence, Shoemaker & Spence ...