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SCC

Geophysical Engineering Limited v. Minister of National Revenue, [1976] CTC 687, 76 DTC 6390

It is further agreed that we shall own beneficially the properties so staked, and shall be responsible for the costs of the staking and recording of the same (and associated expenses) in the following proportions, namely: Goldfields Mining Corporation Limited 3/7ths Joseph H Hirshhorn 3/14ths Mrs Stephen Kay 23/ 140ths Keevil Consultants Limited 1/7th Penelope Explorations Limited 1/40th United Reef Petroleums Limited 1/40th In the event that it may be decided to dispose of these properties in the future and any one or more of us may be unavailable to execute any agreements or documents of transfer in this respect, we each hereby severally appoint Goldfields Mining Corporation Limited trustee to hold the said properties on our respective parts and to dispose of the same as agent for us. in the proportions above set out, and we hereby each appoint Goldfields Mining Corporation Limited our respective attorney for these purposes, this Memorandum constituting its full and complete authority in this regard. ... GOLDFIELDS MINING CORPORATION LIMITED Per: Vice-President Joseph H Hirshhorn Witness to the signature of Joseph H Hirshhorn Mrs Stephen Kay *■ KEEVIL CONSULTANTS LIMITED Per: Witness to the signature of Mrs Stephen Kay President PENELOPE EXPLORATIONS LIMITED Per: President UNITED REEF PETROLEUMS LIMITED it is to be noted that it purports to be an agreement between Goldfields Mining Corporation Limited, Joseph H Hirshhorn, Mrs Stephen Kay, Keevil Consultants Limited, Penelope Explorations Limited, and United Reef Petroleums Limited. ...
SCC

Minister of National Revenue v. Ian G. Wahn, [1969] CTC 61, 69 DTC 5075

At the end of the year 1961 he resigned his partnership in the law firm Borden, Elliott, Kelley & Palmer and established a new firm under the name of Wahn, McAlpine, Mayer, Smith, Creber, Lyons, Torrance & Stevenson. ... In the latter, “income” was defined as meaning ‘‘the annual net profit or gain or gratuity,... ”. ... In such case, clause 17 of the agreement provides for a retiring allowance subject to the condition that he shall not in any way compete with the continuing partnership ’. ...
SCC

(Royal Trust Company Wv. The King), [1949] CTC 59

& W. 171; and that being so, we are remitted to the considerations by which the shares are localized in the place where they may be effectually dealt with. ... & N. 339, 157 E.R. 140, and Brassard v. Smith, [1925] A.C. 371, as well as Erie Beach Co. v. ... & W. 171, as founded on a common principle, as did also Lord Gorell at pp. 38-9. ...
SCC

MNR v. Publishers Guild of Canada Ltd., 57 DTC 1017, [1957] CTC 1 (Ex Ct)

Of these 15 per cent * " cashed-up as the result of the inducements held out, 20.5 per cent were good paying accounts requiring only from 1 to 4 dunning letters, 20 per cent required from 5 to 9 letters, 18.5 per cent from 10 to 20 letters, 16.5 per cent from 21 to 29 letters and 9.5 per cent 30 letters and over. ... C'.I.R. (1927), 11 T.C. 590 at 595, that, " " receivability without receipt for the purpose of Income Tax is nothing at all”: Vide also Dewar v. ... Smail’s work on Accounting Principles and Practice: "‘Income is realized just as fully when an asset is sold for a promise of cash as when it is sold for cash down. Mr. ...
SCC

Nickel Rim Mines Ltd. v. Attorney General (Ontario), [1967] SCR 270

Solicitors for the plaintiff, appellant: Day, Wilson, Campbell & Martin, Toronto. ... Callaghan, Toronto. [1]   [1933] A.C. 533 at pp. 548-49. ...
SCC

James B. McLeod v. The Minister of Customs and Excise, [1917-27] CTC 290, [1920-1940] DTC 85

This subsection, as first enacted by chapter 55 of the statutes of 1919, stated that the "‘income of a beneficiary of an estate shall be deemed to include the amount accruing during each taxation year to which he, his heirs or assigns are entitled from the income of an estate whether distributed or not. The 1920 amendment changed this language, and added the provision concerning income accumulating in trust for the benefit of unascertained persons, or of persons with contingent interests. ... In so far as this definition can be of any help, it considers as income annual gains or profits ‘‘ whether such gains or profits are divided or distributed or not”; but here we are dealing with something which, as received and accumulated by the trustee, is undoubtedly income. ... This subsection provides that: "" (6) The income, for any taxation period, of a beneficiary of any estate or trust of whatsoever nature shall be deemed to include all income accruing to the credit of the taxpayer whether received by him or not during such taxation period. ...
SCC

Home Oil Co. Ltd. v. Minister of National Revenue, [1955] SCR 733

‘In this view “profits reasonably attributable to the production of oil or gas from the well” mean the total income from all the wells operated less the total aggregate outlay related to oil in addition to the purely operating costs. ... Solicitors for the appellant: Nolan, Chambers, Might, Saucier, Peacock & Jones. ... McGrory. 1   [1954] Ex. C.R. 622. ...
SCC

The Queen v. Canada Sugar Refining Co., (1897) 27 SCR 395

C. c. 32—57 & 58 V. c. 33 (D)—58 & 59 V. c. 23 (D). By 57 & 58 Vict. ch. 33, sec. 4, duties are to be levied upon certain specified goods "when such goods are imported into Canada. ... —We must read the statute 58 & 59 Vict. ch. 23, under which, in connection with R. ... & B. 923. [5] 3 ed. p. 298. [6] 1 Gallison 353. [7] 9 Cranch 104. [8] 1 Peters C. ...
SCC

North Bay Mica Company Limited v. Minister of National Revenue, [1958] CTC 208, [1958] DTC 1151

He continued: ‘‘ Well the stringers which led off into the wall rock, in my impression, was, in fact, another dyke that they had done nothing about. Those stringers were, in fact another indications of another dyke I will put it that way’’. ... Support for this contention is sought in the circumstances that if mine ’’ has the first of the two suggested meanings, then, (i) the phrase “certified... to have been operating on mineral deposits” is inapt as it presupposes an entity capable of carrying on operations; and (ii) the draftsman should have substituted for the clause ‘‘that came into production’’ the clause ‘‘that was brought into production’’. ...
SCC

Accessories Machinery Ltd. v. National Revenue (Deputy Director), [1957] SCR 358

All machinery composed wholly or in part of iron or steel, n.o.p., of a class or kind not made in Canada; complete parts of the foregoing 445 g. ... Solicitors for the appellant: Gowling, MacTavish, Osborne & Henderson, Ottawa. ... Solicitors for the respondent, Canadian Electrical Manufacturers' Association: Hume & Martin, Toronto. 1 [1956] Ex. ...

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