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Interveners     Coram: McLachlin C.J. and LeBel, Deschamps, Fish, Abella, Rothstein, Cromwell, Moldaver and Karakatsanis JJ.   ... (McLachlin C.J. and LeBel, Deschamps, Fish, Cromwell, Moldaver and Karakatsanis JJ. concurring)   Abella J.         ... C‑42, s. 3(1)   (f).                     Administrative law — Judicial review — Standard of review — Copyright Board certifying tariff for communication rights in copyrighted music downloaded and streamed from the Internet — Whether decision reviewable on standard of reasonableness or correctness.                     ...

Whenever goods mentioned in Schedules I and II of this Act are imported into Canada or taken out of warehouse, or manufactured or produced in Canada and sold, there shall be imposed, levied and collected, in addition to any other duty or tax that may be payable under this Act or any other statute or law, an excise tax in respect of goods mentioned (a) * * * (b) In Schedule II, at the rate set opposite to each item in the said schedule. ... Solicitors for the appellant: Symons, Heighington & Shaver. Solicitor for the respondent: W. ...

To this argument, the Court thought the answer was: ‘ " That there is not, and cannot be, a sale by the agent to his principal.” ... The " " agent, ‘ ‘ in this instance, would not be paying for himself, but for and on behalf of the principal. ... As section 2(a) of the Act says, ‘‘consumer’’ means any person who within the Province purchases * * * for his own consumption. ...

Yours very truly,                                                                                                                SMITH, NIXON & CO.                                                                                                                ... Solicitors for the appellants: Carrick, O’Connor, Coutts & Crane, Toronto. Solicitors for the respondent: McMillan, Binch, Toronto.   ...

Statute — Construction — Application — Taxation — Exemption — Railway property—Frontage lots — Local improvements, 63 & 64 V. c. 57, s. 18; c. 58, s. 22 (Man.) ... By the "Railway Taxation Act," ch. 57, sec. 18, 63 & 64 Vict. ... " Moreover, as applied to the Revised Statutes of 1902, the words unaffected by any amending Act * * passed concurrently there with would have no point. ...

Terms: Payment due on or before the 20th day of the calendar month following date of shipment * * *; 2% cash discount to be allowed if payment is made on or before the due date. ... MacKenzie, White & Dunsmuir Limited do a large volume of business. ... [Page 494] In determining that question their Lordships treated the word " derived " as synonymous with " arising' or accruing ", and a decision that some income was earned in New South Wales, where it arose or accrued from a trade carried on therein or was derived from lands of the Crown, or arose or accrued from any other source, can, in my view, have no application to the consideration of a statute which imposes a tax upon " the income earned within the province. ...

Section 102 of that legislation read, in part, as follows: For the purpose of the assessment and payment of death duty * * * the estate of a deceased person shall be deemed to include and consist of the following classes of property:— (2) (d) Any property comprised in any gift made by the deceased at any time, whether before or after the passing of this Act, of which bona fide possession and enjoyment has not been assumed by the donee immediately upon the gift and thenceforth retained to the entire exclusion of the deceased, or of any benefit to him of whatsoever kind or in any way whatsoever. ... Solicitors for the respondent: Daly, Thistle, Judson & McTaggart. 1 [1946] Ex. ...

The Company will make an annual contribution of a sum based upon the ratio of its profits to invested capital which will adjust the total monthly contributions made by the Company to the following schedule:   Company Contribution Per Cent of Profits as per cent of to Invested Capital Member Contribution Up to but less than 11% 50% 11% but less than 12% 55% 12% but less than 13% 60% 13% but less than 14% 65% 15% or over 75% 14% but less than 15% 70% 'Invested Capital' shall mean the total of all Capital Stock and Surplus (or equivalent) accounts and Long Term Debt of the Company as of the beginning of the preceding calendar year, as reflected in its printed Annual Report to stockholders. 'Profits' shall mean the Company's Net Income after taxes for the preceding calendar year, as shown in its printed Annual Report to stockholders. ... Year Section IV Section IV   Part A Part B   Monthly Annual  1953 $ 120 None 1954 388 None 1955 903 None 1956                              1,738 $ 84 1957                              3,146 None 1958                              4,175 None 1959                              8,592 None   $19,062 $ 84 Section 79(1) of the Income Tax Act reads: 79 (1) In this Act, an 'employees profit sharing plan' means an arrangement under which payments computed by reference to his profits from his business or by reference to his profits from his business and the profits, if any, from the business of a corporation with whom he does not deal at arm's length are made by an employer to a trustee in trust for the benefit of officers or employees of the employer or of a corporation with whom the employer does not deal at arm's length (whether or not payments are also made to the trustee by the officers or employees), and under which the trustee has, since the commencement of the plan or the end of 1949, whichever is the later, each year allocated either contingently or absolutely to individual officers or employees, (a) all amounts received by him from the employer or from a corporation with whom the employer does not deal at arm's length, and (b) all profits from the trust property (computed without regard to any capital gain made by the trust or capital loss sustained by it at any time since the end of 1955), in such manner that the aggregate of all such amounts and such profits minus such portion thereof as has been paid to beneficiaries under the trust is allocated either contingently or absolutely to officers or employees who are beneficiaries thereunder. ...

Sections 86(1) and 89(1) of the Excise Tax Act read, in part, as follows: 86. (1) There shall be imposed, levied and collected a consumption or sales tax of eight per cent on the sale price of all goods (a) produced or manufactured in Canada (i) payable, in any case other than a case mentioned in subparagraph (ii) hereof, by the producer or manufacturer at the time when the goods are delivered to the purchaser or at the time when the property in the goods passes, whichever is the earlier, and (ii) payable, in a case where the contract for the sale of the goods (including a hire-purchase contract and any other contract under which property in the goods passes upon satisfaction of a condition) provides that the sale price or other consideration shall foe paid to the manufacturer or producer by instalments (whether the contract provides that the goods are to be delivered or property in the goods is to pass before or after payment of any or all instalments), by the producer or manufacturer pro tanto at the time each of the instalments becomes payable in accordance with the terms of the contract; * * * 89. (1) The tax imposed by section eighty-six of this Act shall not apply to the sale or importation of the articles mentioned in Schedule III of this Act. ...

The respondents insist upon the importance of the fact that the furs, in the operations to which they subject them, are neither cut nor " 1 trimmed’ ‘ by them, but that they confine themselves to cleaning, combing and dyeing the raw furs. ... If the skin or fur as cleaned, "‘made pliable’’, to use the expression of one of the witnesses, and dyed by them and sold by them, as "‘merchantable stock-in-trade’’, to use an expression assented to by the principal witness on behalf of the respondents, does not fall within the description 1*** goods produced or manufactured in Canada’’ (sec. 86), it is not, at all events, immediately obvious how it can fall within the description "‘goods * * * manufactured or produced in Canada’’ within the meaning of sec. 87. ... It is not easy to see why a raw fur which is separated from the animal upon which it grew, when combed, ‘ 1 made pliable” and dyed and thereby turned into ‘‘merchantable stock-in-trade’’, has not become something which is ‘‘produced’’ if the term " 1 produced” is properly applicable to such things as ‘‘pulpwood’’ and ‘‘tan bark’’. ...