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On the first $250 of the- income or any portion thereof, 22 per centum per annum; or i ” Paragraph AA of the First Schedule: " " Rate of tax applicable to investment income of persons other than corporations and joint stock companies, under subsection one of section nine of this Act, On investment income in excess of $1, 800—four per centum.” ... :invest- ment income ‘ ‘ and that must mean investment income as defined in the Act. In my view, ‘‘earned income ‘‘ was defined solely for the purpose of then defining " " investment income ‘ and, for the purpose of this case, it is sufficient to say that in general terms investment income is any income not defined in the Act as ‘‘earned income’’. ...

A2) — Freda/1494 (Ex. A3 No. 1494 (Ex. A6) Account No. 1494. Under (Ex. ... There is some evidence, therefore, that the appellant’s husband was in business and that the appellant through the agency of her husband may have been engaged in ‘ ‘ an adventure or concern in the nature of trade ’ ’ within Section 139(1) (e). ... M.N.R., [1964] C.T.C. 519 at 921, Cattanach, J. stated: “It follows that in my view, when a person embarks on an adventure in the nature of a money lender’s trade and earns a similar profit the profit he acquired is a profit from an adventure in the nature of trade. ’ ’ In the present case, the appellant’s husband, who entered into the transactions as the appellant’s agent, was not called as a witness to prove the transactions, their nature, the nature of his business and the extent to which the appellant’s transactions were intermingled in his business. ...

Attached to the said consent was a schedule of purchases and sales of land made by the late Adolorata Fabi and entitled ‘‘ Mrs. Adolorata Fabi ’ ’. Also a second schedule, marked ‘‘ Appendix 1 ’ of purchases and sales covering four pages which were made jointly by Samuel Fabi and his mother in connection with lots 4 and 5 (Brault Farm). ...

.: “‘ Assessments will be reported and approved on the above basis.’’ ... Para. 1 says " 1 that in respect of timber cut in the taxation year... operators be given a special allowance. ‘ ‘ Para. 5 says ‘‘that the special allowance be not granted in respect of pulp-wood... operations.” Para. 1 uses the word ‘‘operators’’; para. 5 the word " " operations. ” It is evident that out of general logging operations an exception of pulp-wood operators is made. ...

(b) There shall be imposed, levied and collected upon all goods enumerated in schedule II to this Part, * * * when any such goods are manufactured or produced in Canada and sold * * *, the rate of excise tax set opposite to each item in said schedule II.” The said schedule mentions ‘‘ale, beer, porter and stout, per gallon * * * twelve and one-half cents,” and also cigars and carbonic acid gas. ... In the case of the sales tax, which is imposed by s. 19BBB, subsee. 1, of the same statute as amended, the relevant provision is as follows: “In addition to any duty or tax that may be payable under this Part, * * * there shall be imposed, levied and collected a consumption or sales tax of five per cent on the sale price of all goods produced or manufactured in Canada *** which tax shall be payable by the producer or manufacturer at the time of the sale by him; * * *. ...

Under section 103 of the Companies Act, 1929, of the United Kingdom, 19 & 20 Geo. ... If " " Canadian ’ ‘ means ‘ ‘ resident in Canada ‘ ‘ it cannot also mean "‘non-resident in Canada.” ... The term " ‘ Canadian, when applied to a company, should be dealt with similarly and be regarded as meaning a company incorporated in Canada. ...

See. 9B, ss. 2 (a) of the Act is as follows: In addition to any other tax imposed by this Act an income tax of five per centum is hereby imposed on all persons who are non-residents of Canada in respect of (a) All dividends received from Canadian debtors irrespective of the currency in which the payment is made * * * Subsec. 4 of s. 9B provides that: In the case of interest or dividends in respect of fully registered shares, bonds, debentures, mortgages or any other obligations, the taxes imposed by this section shall be collected by the debtor who shall withhold five per centum of the interest or dividend on the obligation and remit the same to the Receiver-General of Canada. By s. 2 (b) of the Act ‘ dividends ‘ ‘ include ‘‘stock dividends. ’’ The defendant is a company incorporated under the laws of the Dominion of. ... The defendant company did not collect or withhold, or pay, the tax in respect of the said 4,907 shares of its capital stock allotted to Johnson Matthey & Company Limited. ...

BETWEEN: ROY OTTO GERMAN, of the City of Calgary, in the Province of Alberta (Secretary) (hereinafter referred to as the ‘‘ Husband’’), OF THE FIRST PART, — and — MURIEL EVA GERMAN of the City of Calgary, in the Province of Alberta, Married Woman, (hereinafter referred to as the "Wife"’) OF THE SECOND PART. ... The reference in the agreement to the " " dower consent ’ ’ of the wife raises a question as to what it is and what are its purpose and effect. ... {Signature of Spouse.) ’ ’ By Section 6(1)(c), it is further required that the spouse acknowledge apart from the married person: "(c) that the spouse consents to the disposition for the purpose of giving up the life estate and other dower rights in the homestead given by The Dower Act, 1948, to the extent necessary to give effect to the said disposition; ‘ ‘ From the foregoing, it appears that the purpose of the consent is to give up (rather than to convey to anyone) the rights which the spouse has in the homestead by virtue of the provisions of the Dower Act. ...

“I, therefore, told my office nurse, ’ ’ says Dr. Appleby, ‘‘ to deduct from my income the pay-off share since no tax was due on such sums.”’ ... In June, 1946, he began working as accountant and‘ ‘ income tax advisor ’ ’ for Dr. ... The witness, required to elucidate item 12 of Schedule C ‘‘ Payment to accountant debited to fees account in General Ledger not allowable as an expense: $500 ’ ’, answers that this was an advance to him for fees and travelling expenses. ...

The plaintiff alternatively claims the sum of $1,827.34, plus a penalty of $500.00 under the provisions of Section 119 of said chapter 179, as amended, now Section 61 of chapter 100, R.S.C. 1952, which is as follows: ‘‘ 61. ... The supplement to Murray’s English Dictionary, published in 1933, the original of which was published in 1893, gives what was then a recent meaning of the word ‘ ‘ component ’ ’ as follows: “applied specially to the separate parts of motor cars and bicycles. Hence attributively and combined as component maker, component built. ’ ’ While the circumstances provided for thereby are not before this Court, the words used in subsection (8) of Section 80 of chapter 179, R.S.C. 1927, as amended, now Section 23(3), R.S.C. 1952, are of assistance: “23. (3) The tax imposed by this section or by section 28 is not payable in the case of goods that are purchased or imported by a manufacturer licensed under this Part or under section 129 of The Excise Act, and that are to be incorporated into and form a constituent or component part of an article or product that is subject to an excise tax under this Part or to an excise duty under The Excise Act.” ...