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When asked why he considered the obligation under a credit note as current liability and the obligation under a warranty as contingent, he said: ‘.. the credit note, while it is a liability, is also an existing obligation today. ... At page 179 [87] he refers to the English case of Edward Collins & Sons, Ltd v The Commissioners of Inland Revenue (1924), 12 TC 773, in which it was held that the deduction for an apprehended future loss was not permissible. ...

LaForest J. highlighted the fact that, in this section, “... Indians holding lands or personal property in their own right outside the reserve hold that property on the same basis as all other similarly situated property holders”[FN24: <p><em>Supra</em>note 21 at 128. ... The respondent in this case has suggested, as potential locations of the employer, the Department of Supply & Services office in Winnipeg, the City of Ottawa and the location of the Hospital itself. ...

A definition of “sham” is found in the matter of Snook v London & West Riding Investments Ltd, [1967] 1 All ER 518, where Diplock, LJ at page 528 says: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance Ltd. and the defendants were a sham, it is, I. think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ... An analysis of schemes similar, in principle, to the one of the present instance, is found in Lupton v FA & AB, Ltd, [1968] 2 All ER 1042, where we read, at page 1051, these remarks of Megarry, J: If on analysis it is found that the greater part of the transaction consists of elements for which there is some trading purpose or explanation (whether ordinary or extraordinary), then the presence of what I may call “fiscal elements’’, inserted solely or mainly for the purpose of producing a fiscal benefit, may not suffice to deprive the transaction of its trading status. ...

The shares were not actually “ allotted or issued” by the company to the four members of the syndicate until September 25, 1951. ... The meaning of “ benefit of whatever kind” is clearly quite broad;... ...

For those situations where the T2113 designation and T2114 information return are both late, if eligible R & D expenditures were carried out to offset the Part VIII tax liability, we will: a. accept the late-filed designation; b. apply the LFP on the designation; payment will be Collections responsibility and not a determining factor in our acceptance of the designation; and c. allow the investors' S.R.T.C.s as claimed. 2. If the R & D expenditures were not attempted, not eligible, or partially eligible: a. the designation will not be accepted; b. the LFP on the designation will be refunded, if paid; and c. the investor's S.R.T.C.s will be disallowed. ...

The classical exposition as to what constitutes a sham was given by Diplock, LJ (as he then was) when he said in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 518 at page 528: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd and the defendants were a “sham”, it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ... Finsbury Securities Ltd v Bishop (Inspector of Taxes), [1965] 1 All ER 530, and FA & AB Ltd v Lupton (Inspector of Taxes), [1971] 3 At ER 948, are not helpful in resolving the problem before me. ...

PHILLIPS & VINEBERG Per: Philip. F Vineberg, Solicitor for the Appellant DATED AT MONTREAL, this 17th day of November 1977. ... In the words of Thurlow, J in McMahon v MNR, [1959] CTC 166 at 171; 59 DTC 1109 at 1111: “... ...

One statement to this effect is found in the judgment of Thurlow, J, as he then was, in the Court of Appeal in the case of MNR v Yonge- Eglinton Building Limited, [1974] FC 637 at 653; [1974] CTC 209 at 219;* 74 DTC 6180 at 6187, where he states: Principal Interest Total Total (a) November 28th, 1968 660,000.00 — 660,000.00 (b) July 20th, 1969 311,169.00 14,031.19 325,200.19 (c) August 25th, 1970 233,101.00 28,431.74 261,532.74 (d) October 4th, 1971 597,377.00 119,262.60 716,639.60 $1,801,647.00 $161,725.53 $1,963,372.53 No witnesses were called.... ... Reference was also made to the case of Raja’s Commercial College v Gian Singh & Co Ltd, [1977] AC 312, in which the Simpson v Executors of Bonner Maurice and Riches v Westminster Bank Ltd cases (supra) were discussed in detail. ...

The Minister assessed the company to sales tax on the basis that the processed marble constituted “goods produced or manufactured in Canada” under paragraph 30(1)(a) of the Excise Tax Act, RSC 1952, ¢ 100. ... It was stated in this way by Parke, B (Becke v Smith (1836), 2 M & W 191 at p 195): “it is a very useful rule, in the construction of a statute, to adhere to the ordinary meaning of the words used, and to the grammatical construction, unless that is at variance with the intention of the legislature, to be collected from the statute itself... ...

In 1953 he purchased the assets owned by the 1935 company from the estates of the then deceased original partners and shareholders and incorporated a new company under the name of McCallum Hill & Co Limited (hereinafter referred to as McCailum Hill) to continue the business of the former company. ... Prior to this event Mr Hill had commissioned Larry Smith & Co of Seattle, Washington, a firm of real estate consultants who also describe themselves as economic consultants, to prepare a brochure of the proposed shopping centre including a site plan of the centre showing the location and description of retail outlets and a drawing of the centre, both prepared by H K Black, an architect in Regina engaged by Mr Hill to do this, a plan of the development the same as the general Outline Plan approved by the City Council on December 23, 1957, which was a year subsequent to the completion of the brochure in December 1956, to demonstrate the accessability of the site, a review of the trade area to be served, the income and buying power of the residents of that area, the sales potential and the prospect of increase therein and a comparison of the Hillsdale site with competing sites. ...