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Revenu — Impôt sur le revenu — Vente d'une concession forestière après que le bois a été enlevé — Est-ce une disposition de biens susceptibles de dépréciation — Coût en capital à titre d'allocation — Coût en capital non déprécié — Loi de l'Impôt sur le revenu, S.R.C. 1952, c. 148, arts. 11(1)(a), (b), 20(1), 20(5) (a), (c), (e) — Règlements de l'Impôt sur le revenu, arts. 1100(1)(e), 1100(2), 1101(3)(a), (b), 1102((2), Cédule C. ... (a) of ss. (1) of s. 11 …" and is therefore not "depreciable property of a taxpayer" within the meaning of s. 20 (5) (a). ... Solicitors for the appellant: Meredith, Marshall, McConnell & Scott, Vancouver. ...

Speaking of the position of the trustees, he said, [1933] S.C.R. at 293: ‘ ‘ Les ‘trustees’ n’en seront cependant pas propriétaires, dans le sens absolu du mot. ... & Bro. 648, H.L. It had previously been described as “a rule of common sense as strong as can be’’, by Lord Ellenborough, in Doe v. ... Leathern, [1901] A.C. 495 at 506: ‘*,.. a case is only an authority for what it actually decides. ...

Speaking of the position of the trustees, he said, [1933] S.C.R. at 293: ‘ ‘ Les ‘trustees’ n’en seront cependant pas propriétaires, dans le sens absolu du mot. ... & Bro. 648, H.L. It had previously been described as “a rule of common sense as strong as can be’’, by Lord Ellenborough, in Doe v. ... Leathern, [1901] A.C. 495 at 506: ‘*,.. a case is only an authority for what it actually decides. ...

“Income” is defined by Section 3(1) of the statute to mean, inter alia, ‘ ‘... the annual net profit or gain or gratuity, whether ascertained and capable of computation as being... salary...” ... The appellant deposed that he then told Black that there was no assurance that anybody would get anything and that the latter had said that while there might not be anything for the committees, nevertheless, in organizations of that character ‘‘they generally arranged for payment of the solicitor’s fees or counsel fees and in big companies the fees are generally large’’, and Black ‘‘ was willing to offer me to split his fee ’ ’ for the purpose of developing the mining claims to which I have already referred. ... Section 3 provides: “ (1)... Income ’ means the annual net profit or gain or gratuity, whether ascertained and capable of computation as being wages, salary, or other fixed amount, or unascertained as being fees or emoluments... directly or indirectly received by a person from any office or employment... and also the annual profit or gain from any other source including...” ...

Composers', Authors & Publishers Association of Canada, Ltd. v. ... Solicitors for the appellant: Crease, Davey, Lawson, Davis, Gordon & Baker. ... & E. 1 at 7. 4 (1838) 6 A. & E. 56 at 68. 5 [1891] 2 Q.B. 699 at 705. 6 [1921] 2 A.C. 384 at 390. 7 [1921] 63 Can. ...

& sub. 1974-75-76 (Can.), c. 76, s. 14]—Interpretation Act, R.S.C. 1970, c. ... By 1964-65 (Can.), c. 52, s. 2, the short title of the Companies Act was changed to the Canada   Corporations Act  ; thereafter Eldorado was incorporated under Part I of the Canada   Corporations Act  . ... Solicitors for the respondent Uranium Canada Ltd.: Gowling & Henderson, Ottawa.   ...

Solicitors for the defendant, appellant: Miller, Maki & Inch, Sudbury. Solicitors for the plaintiff, respondent: Osler, Hoskin & Harcourt, Toronto ...   [1] [1958] O.R. 168, 12 D.L.R. (2d) 648. [2] [1958] O.R. 168, 12 D.L.R. (2d) 648. [3] [1891] 2 Q.B. 115. [4] (1921), 49 O.L.R. 214 at 217, 62 D.L.R. 619. [5] [1931] O.R. 640, 4 D.L.R. 239; affirmed [1933] S.C.R. 321, 3 D.L.R. 15. ...

By Section 5 of that statute it was provided that a company theretofore incorporated by memorandum of association, upon compliance with prescribed formalities, might deliver to the Registrar of Companies a copy of its charter and regulations and its certificate of incorporation and receive a certificate of what was called the ‘ ‘ reincorporation ’ ’ and registration of the company as a company under the new Act. ... The powers so vested in every company incorporated under the terms of the Act of 1919 and in any company which might under the provisions of Section 51 of the Act, by ordinary resolution, alter its memorandum of association so as to include any or all of the powers referred to in Section 22, include, it is to be noted, the right:— “ (a) To purchase, take on lease or in exchange, hire, or otherwise acquire and hold any real and personal property and many rights or privileges which the Company may think necessary or convenient for the purposes of its business; ’ ’. (a) To sell or dispose of the undertaking of the company or any part thereof for such consideration as the company may think fit... ’ ’ and (b) To sell, improve, manage, develop, exchange, lease, dispose of, turn to account, or otherwise deal with all or any part of the property and rights of the company.” ...

And that is what, in my opinion, the testator has done. ’ ’ On a cité également la cause de Curran v. ... Dans ce jugement, à la page 305, M. le juge Rinfret dit: " " Il est évident que les fiduciaires sont tout autre chose que des dépositaires ou des administrateurs ordinaires. ... L’article 3 dit en effet: " " Tout bien mobilier ou immobilier, dont la propriété, l’usufruit ou la jouissance est transmis par décès en ligne, etc., etc., etc. ...

But it is equally well established that enhanced values obtained from realization or conversion of securities may be so assessable where what is done is not merely a realization or change of investment, but an act done in what is truly the carrying on, or carrying out, of a business. ‘ ‘ The learned members of the Income Tax Appeal Board, having heard the evidence of the appellant, did not accept his statement that he had caused to be built these various properties for the purposes of investment and concluded that in truth he was carrying on the business of constructing them for the purpose of resale at a profit. ...