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& C. 480, 489; 6 Bligh 1, 21; Perry v. Skinner 2 M.& & W. 471, 475; Attorney General v. ... & W. 378, 398; Richards v. McBride L.R. 8 Q.B.D. 119,122; Christopherson v. ... & E. 434; Esdaile v. Maclean 15 M. &W. 277; The Eastern Counties and The London & Blackwall Railway Companies v. ...

During the whole of the taxation years of Polestar now under review there were 5,000 issued and outstanding common shares each carrying one vote per share held as follows: ⅕ by Ardwell Holdings Limited 1,667 ⅕ by Bradford Investments Limited 1,666 ⅑ by Doric Developments Limited 556 ⅑ by Loring Developments Limited 556 ⅑ by Adair Developments Limited 555 Total.. 5,000 At the same time the shares in other companies in the Okun group were held in the same manner except that in some instances Loring Developments Limited and El Ciudad Limited were interchanged. ...

In the taxation years in question (1962, 1963 and 1964) the voting shares were held as follows: Joseph Lipetz — 249 Edna Lipetz — 1 In 1961 North West Distributors Ltd., as a result of its advertisement by Lipetz, met Henry John Whyte who was familiar with the steel business and that resulted in an arrangement between Lipetz and Whyte to form a company to engage in the business of importing steel which Whyte would manage and for which Lipetz would provide the moneys by loan. ...

Hattin, Moses & Co., Accountants, were the auditors of Shields Construction Co., and H. ... Victor Shields, the other partner shown, is our client’s son who is a minor. ’ ’ and much the same comment is made for the previous year. ... It shows the respondent as sole owner and that the financial statement was audited by Hattin, Moses & Co. ...

Foscolo, Mango & Co., [1932] A.C. 328; Gramophone and Typewriter, Lid. v. ... Williams, [1942] A.C, 541 at page 549. 5 * The necessity is based on the desirability of avoiding double or multiple taxation. 6 * See also Brown, Gow, Wilson et al. v. ... Foscolo, Mango & Co., [1982] A.C. 328 at 350. 10 [1963] S.C.R. 131; [1963] C.T.C. 51. 11 * The problem is described as follows in a note by Arnold D. ...

In these appeals, as in the appeals of Alpine Dry wall & Decorating Ltd., the sole question is whether the appellant is associated with Jager Holdings (Calgary) Limited within the meaning of the word ‘‘associated’’ as used in Section 39 of the Income Tax Act. ... In view of the conclusion I reached in Vineland Quarries & Crushed Stone Limited v. ... For the reasons expressed in the appeals of Alpine Drywall & Decorating Ltd., which are being filed concurrently herewith, I must conclude that it does not. ...

At all material times also the appellant, Morgan Securities Limited, was a wholly owned subsidiary of Houston & Company Limited, brokers and underwriters, a member of the Toronto Stock Exchange, or of the individual partners of the predecessor partnership firm, Houston & Company. ... Tetlaw, controlling shareholders of Houston & Company Limited, and partners in the predecessor partnership firm of Houston & Company, caused a private Ontario company to be incorporated under the name of Parkton Limited, and then caused Parkton Limited in September 1955, to buy all the shares of three car transport companies from one Harold Hoare, namely Gillson Automobile Transport Limited, Roadway Carriers Limited, and Automobile Transport Limited for $690,000 which was paid for as follows: firstly, by a note to Harold Hoare for $65,000 and by issuing and delivering 250,000 first preference shares of Parkton Limited to him and by paying him $375,000 in cash. ... Thus subject to the note of $65,000 and the $300,000 first preference shares of Parkton Limited held by Harold Hoare, at the date of this acquisition the major shareholders of Houston & Company Limited, or its predecessor partnership, controlled Parkton Limited through the appellant, that is to say James Houston, Reginald H. ...

& G. Lagacé Inc. and Adrien Lagacé Inc. — was engaged at the relevant time in a business of trading in land or that the appellants, in negotiating the various acquisition and disposition transactions with the third parties, were doing so as agents or employees of one or other of the companies controlled by them.) ... That contract reads as follows: Entente entre Georges & Eugène Lagacé et J. ... & G. Lagacé Inc., each purport to be purchase transactions involving the payments of large sums of money. ...

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Fisher, from whose decisions the appeals are now taken, expressed his opinion on the matters in appeal in this case as follows: ‘“ As to the amounts received in the years 1946 and 1947 in respect of the gas lease, the pipe deal, and the salt lease, I have reached the conclusion that these were capital receipts arising out of isolated transactions which did not form part of the ordinary business of the appellant. ... Then, by the agreement, the respondent covenanted that in consideration of the premises and of one dollar "‘I hereby agree that I shall from this date forward hold the beneficial interest above referred to in trust for Bata Petroleums Limited so that they may receive through me all benefits which might otherwise be derived by me from the said lands and the said reservation or permit upon the following conditions: ‘ ‘ Bata, by the terms thereof, agreed forthwith to issue to Turnbull or his order "‘the shares above referred to’’ (the number of which was not specified in the agreement) and to assume all the obligations for which Turnbull might be liable under the permit or reservation. ... I think that Fell in his evidence correctly stated the purpose of the acquisition of the salt rights when he said that it was his intention " to get something good for the company”. ...