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The proper amount payable is determined by reference to 1962 profits of Borden, Elliott, Kelley & Palmer. ... Solicitors for the respondent: Robertson, Lane, Perrett, Frankish & Estey, Toronto ...   [1] [1968] C.T.C. 5, 68 D.T.C. 5023. [2] (1865), 6 B. & S. 794 at 801, 122 E.R. 1386. [3] [1967] S.C.R. 822, 61 W.W.R. 727, [1968] 2 C.C.C. 129, 2 C.R.N.S. 319. [4] [1968] C.T.C. 5, 68 D.T.C. 5023. [5] [1964] S.C.R. 177, [1963] C.T.C. 571, 63 D.T.C. 1378, 42 D.L.R. (2d) 492. ...

Whereas the original agreement had called for payment for the appellant’s services in Canadian dollars, the new clause 12.2 provided that, in the event of the appellant financing the construction of its pipeline in whole, or in part, by means of “U.S. pay securities’’ sold prior to December 31, 1964, then each shipper ‘‘shall in its payment of its said monthly cost of service charge ’ ’ substitute United States dollars for Canadian dollars, to the extent provided in the agreement, not to exceed 66% of the monthly cost of service charge. ...

Ltd. and Westcoast Transmission Company Limited, herein referred to as ‘ ‘ the shippers’’, to receive, transport and deliver daily volumes of gas in accordance with the terms and conditions of the contract, by means of a gas transmission system, which the appellant undertook to construct. ...

The relevant sections of The Income Tax Act are as follows: “42. (1) The Minister shall, with all due despatch, examine each return of income and assess the tax for the taxation year and the interest and penalties, if any, payable. (2) After examination of a return, the Minister shall send a notice of assessment to the person by whom the return was filed. (4) The Minister may at any time assess tax, interest or penalties and may (a) at any time, if the taxpayer or person filing the return has made any misrepresentation or committed any fraud in filing the return or supplying information under this Act, and (b) within 6 years from the day of an original assessment in any other case, re-assess or make additional assessments. (5) The Minister is not bound by a return or information supplied by or on behalf of a taxpayer and, in making an assessment, may, notwithstanding a return or information so supplied or if no return has been filed, assess the tax payable under this Part. (6) An assessment shall, subject to being varied or vacated on an objection or appeal under this Part and subject to a re-assessment, be deemed to be valid and binding notwithstanding any error, defect or omission therein or in any proceeding under this Act relating thereto. 50. (6) No interest under this section upon the amount by which the unpaid taxes exceed the amount estimated under section 41 is payable in respect of the period beginning 12 months after the day fixed by this Act for filing the return of the taxpayer’s income upon which the taxes are payable or 12 months after the return was actually filed, whichever was later, and ending 30 days from the day of mailing of the notice of the original assessment for the taxation year. ’ ’ The contention of the appellant is that, on the admitted facts, the notice mailed on July 22, 1953, was a nullity because, before it was mailed and at the time it was mailed, it had been decided to conduct a further examination of the appellant’s return. ...

The dispute is as to whether these. amounts were paid " " pursuant to... a written agreement as alimony or other allowance payable on a periodic basis for the maintenance of the recipient thereof’’, these being the words of Section 11(1) (1) relied on by the appellant, It is necessary to state the facts in some detail. ...

Legal expense $10,000.00 Long distance Telephone expense 340.80 Travelling expense 3,016.26 $13,357.06 Upon your request I shall be pleased to furnish details and receipted bills, and such further information as you may require. ’ ’ The ‘‘Canadian Company” referred to in this letter is Concrete Column Clamps Limited, which was incorporated some years ago under the Dominion Companies Act. ...

LESQUELS font les conventions suivantes: (A) — LA PARTIE DE PREMIÈRE part s’engage à emprunter la somme capitale de DEUX CENT SOIXANTE-QUINZE MILLE dollars ($275,000.00) par voie d’émission d’actions privilégiées aux taux et conditions ci-après spécifiées; (B) — Le but de cet emprunt est de consolider une dette d’environ soixante-cinq mille dollars ($65,000.00) et de parachever certaines constructions déjà commencées; (C) — Pour prélever ladite somme de $275,000.00, la partie D première PART s’oblige d’utiliser les services de la PARTIE de DEUXIÈME PART exclusivement aux conditions ci-après apposées; CES FAITS étant ÉTABLIS, les parties aux présentes les précisent de la façon suivante: Conditions DU PRET 1 — Montant: DEUX CENT SOIXANTE-QUINZE MIL dollars ($275,000.00); 2° — Durée: Dix ans (10) à compter du quinze juillet prochain mil neuf cent quarante-six; 3° — Taux: CINQ POUR CENT L’AN (5%) payable semi- annuellement les quinzièmes jours de janvier et de juillet de chaque année, le premier versement d’intérêt devenant dû le quinze juillet de l’an prochain et ensuite semi-annuellement comme susdit; l’intérêt sera payable au domicile du souscripteur de l’action; 4° — REMBOURSEMENT: VINGT-SEPT MILLE CINQ CENTS dollars ($27,500.00) au minimum annuellement par voie de tirage au sort à une période laissée au choix de LA PARTIE DE PREMIÈRE PART; Les remboursements sur le capital s’effectueront au bureau principal de LA PARTIE DE PREMIÈRE PART et il devra être donné aux détenteurs immatriculés de telles actions un avis de soixante jours les informant que une ou toutes leurs actions leur seront payées. ... The fact of certificate A-6 reads as follows: ‘ Certificate ACTIONS 2 ACTIONS No. ... Conformément aux dispositions du 2e paragraphe de l’article 5 de la loi des sociétés coopératives agricoles, les actions privilégiées ne confèrent pas à leurs détenteurs le droit d’assister et de voter aux assemblées générales. ’ ’ The only difference of substance between the front of Certificate A-6 and that of Certificate A-l is that in the latter the date of the resolution of the board of directors is given as July 8, 1943. ...

Where general expenses are incurred to earn both taxable and non-taxable income the Minister shall have power to apportion the said expenses. ‘ ‘ It has been shown that in 1947 the appellant received $240,000 as dividends from Macdonalds, while it paid as interest on its debentures the sum of $44,876.72; and that in 1948 it received $610,000 in dividends from Macdonalds and paid, as interest on its debentures, $97,500. ... (ce) an amount paid in the year or payable in respect of the year (depending upon the method regularly followed by the taxpayer in computing his income), pursuant to a legal obligation to pay interest on (i) borrowed money used for the purpose of earning income from a business or property (other than property the income from which would be exempt), or (ii) an amount payable for property acquired for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt), or a reasonable amount in respect thereof, whichever is the lesser. ‘ ’ The language in (i) ‘‘used for the purpose of earning income from a business’’ corresponds with that of Section 5(1) (b) of the repealed Act and to what has been said on the latter there is nothing to be added: the business of the subsidiary is not that of the company. The word " property” is introduced in paragraphs (i) and (i) but I cannot see that it can help the appellant; the language "‘borrowed money used for the purpose of earning income from... property (other than property the income from which is exempt)” in (i) means the income produced by the exploitation of the property itself. ...

Parke, Davis & Co., [1968] S.C.R. 307, 55 C.P.R. 111, reversing 53 C.P.R. 236, restoring 46 C.P.R. 171; Burton Parsons Inc. v. ... James Booth, respondent’s chemical expert witness, agreed that Funk & Wagnalls’ definition did not “fit very well”. ... Solicitors for the appellant: Martineau, Walker, Allison, Beaulieu, Phelan & MacKell, Montreal. ...

Vancouver where the amounts paid for delivery have been less than the cost of delivery at Vancouver, by an equitable difference (according to market prices obtained for sour cream, sweet cream, and whole milk Provided always that from and out of the moneys realized from the sale of milk and/or cream during the term of this agreement the Association may deduct and retain from month to month such amounts for the purposes of the Association as its Directors may from time to time decide, which amounts shall not exceed in all 10 per cent. of the amount realized from the sale of the said milk and/or cream, and said amounts so deducted and retained by the Association together with similar amounts deducted and retained by. the Association from all other Producers delivering to the Association shall be a fund in the hands of the Association to be expended as follows:— " 4 (a) To provide for all losses, costs, charges and expenses incurred by the Association in carrying on its business together with a reasonable allowance for depreciation of all plants and equipment. ... These moneys deducted and retained by the Association " ‘for the purposes of the Association’’ are to be expended:—_ (1) In providing for all losses, costs, charges and expenses of the business of the Association, including an allowance for depreciation of plant and equipment, (2) in establishing a reserve fund in compliance with the statute, (3) in payment of a ‘‘cash dividend’’ to the shareholders of the Association, at such rate as shall be ‘‘fixed by the said Association, not exceeding eight per cent. per annum, ‘ ‘ (4) as to any surplus, after providing for these requirements, in paying a sum, not to exceed 21% per cent. of the total moneys realized, in the purchase of lands, buildings, machinery or equipment, or ‘‘ in making any other investment/’ deemed to be "‘for the benefit of the Association”; and in disposing of any balance of the surplus in such manner as the Association may determine in annual general meeting. ... Admittedly, by the contract, the moneys realized from the sale of milk and cream, were to be distributed " 4 about the middle and the end of each month,’’ or at such periods as might be fixed by the Association, subject to the monthly deduction above mentioned, which is not to exceed ten per cent. of the total amount realized from sales. ...