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Counsel for the respondent put great emphasis on the statements which appear in Article IV F of the plan to the effect that the employer's contribution is "on behalf of and as an absolute benefit for (the) member" and that such contribution ” shall be regarded as additional compensation paid to (the member)"; they likewise attach much importance to the fact that income taxes for participating employees are withheld not only from their wages but also from the employer's contribution. ...

On general principles then, the tax imposed by section 6A qualifies as a direct tax; see Canadian Industrial Gas & Oil Ltd v The Government of Saskatchewan, [1978] 2 S.C.R. 545. ...

Counsel for the Minister was frank to concede that the transactions between Companies and Paper were real and did not constitute a “sham” within the definition of that word in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 519 where Lord Diplock said at 528:... it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...

In each Province the Legislature may exclusively make Laws in relation to Matters coming within the Classes of Subject next hereinafter enumerated; that is to say, — 14. ...

During the years 1965 to 1969 an average break-down of the cor- porate accused’s sales to retail florists per province were as follows: Alberta 54%, Saskatchewan 29%, Manitoba 11 %, British Columbia 5% and Ontario 1%. ...

At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles: "... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act and the intention of Parliament". ...

.: — This is an appeal from a judgment of the Trial Division allowing in part the respondent’s appeal from the reassessment of its income tax for the 1978 taxation year. ...

In The Queen v Ken & Ray’s Collins Bay Supermarket Limited, [1975] CTC 504; 75 DTC 5346, Kerr, J decided that a somewhat similar management bonuses arrangement was contingent on the necessary funds being available. ...

The appellant produced cases, uncontested by the respondent, which have held interest expense to be deductible where the interest expense exceeds the income from property (Alberta & Southern Gas Co. v. ...

("Allarco '); and (c) 840 owned all of the issued shares of 348841 Alberta Ltd. ...