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Solicitors for the respondent: Smart & Biggar. [1] [1942] Ex. C.R. 33; [1942] 2 D.L.R. 337. [2] The judgment in the Privy Council is in 55 R.P.C. 125; [1938] 2 D.L.R. 145. [3] [1941] S.C.R. 19. [4] [1938] 2 D.L.R, 145, at 149. ...

. … …the criteria for intervening are closely bound up with the concept of ultra vires. ... Solicitors for the appellants: Byers, Casgrain, McNally, Dingle, Benn & Lefebvre, Montreal. ...   [1] Oral reasons from the Bench. ...

Relevant Statutory Provisions The relevant statutory provisions are as follows: Income Tax Act, R.S.C. 1952, c. 148, as amended 9.(1) Subject to this Part, a taxpayer’s income for a taxation year from a business or property is his profit therefrom for the year. (2) Subject to section 31, a taxpayer’s loss for a taxation year from a business or property is the amount of his loss, if any, for the taxation year from that source computed by applying the provisions of this Act respecting computation of income from that source mutatis mutandis. (3) In this Act, “income from a property ” does not include any capital gain from the disposition of that property and “loss from a propert" does not include any capital loss from the disposition of that property. 13.(1) Where, at the end of a taxation year, the aggregate of all amounts determined under subparagraphs (21)((iii) to (viii) in respect of depreciable property of a particular prescribed class of a taxpayer exceeds the aggregate of all amounts determined under subparagraphs (21)((i) to (11.1) in respect of depreciable property of that class of the taxpayer, the excess shall be included in computing the income of the taxpayer for that taxation year. 88.(1) Where a taxable Canadian corporation (in this subsection referred to as the “subsidiary”) has been wound up after May 6, 1974 and not less than 90% of the issued shares of each class of the capital stock of the subsidiary were, immediately before the winding-up, owned by another taxable Canadian corporation (in this subsection referred to as the “parent”) and all of the shares of the subsidiary that were not owned by the parent immediately before the winding-up were owned at that time by persons with whom the parent was dealing at arm’s length, notwithstanding any other provision of this Act, the following rules apply: (a)...each property of the subsidiary that was distributed to the parent on the winding-up shall be deemed to have been disposed of by the subsidiary for proceeds equal to, (iii) in the case of any other property, the cost amount to the subsidiary of the property immediately before the winding-up; (f) where property that was depreciable property of a prescribed class of the subsidiary has been distributed to the parent on the winding-up and the capital cost to the subsidiary of the property exceeds the amount deemed by paragraph (a) to be the subsidiary’s proceeds of disposition thereof, for the purposes of sections 13 and 20 and any regulations made under paragraph 20(1)(a), (i) notwithstanding paragraph (c) the capital cost to the parent of the property shall be deemed to be the amount that was the capital cost thereof to the subsidiary, and (ii) the excess shall be deemed to have been allowed to the parent in respect of the property under regulations made under paragraph 20(1)(a) in computing income for taxation years before the acquisition by the parent of the property. ... The dissolved partnership may then have been reconstituted as a new partnership between the remaining eligible partners: Hudgell Yeates & Co. v. ...

Solicitors for the respondent: Ogilvy, Cope, Porteous, Hansard, Marler, Montgomery & Renault, Montreal ...   [1] [1969] C.T.C. 257, 69 D.T.C. 5185. [2] [1969] C.T.C. 257. 69 D.T.C. 5185 [3] [1958] S.C.R. 597 at 601, [1958] C.T.C. 208, 58 D.T.C. 1151, 15 D.L.R. (2d) 1. ...

S-s. 1 of s. 3 of the Income War Tax Act, in so far as it affects the present matter, reads:— For the purposes of this Act "income" means the annual net profit or gain … being profits from a trade or commercial or financial or other business or calling … and shall include the interest, dividends or profits directly or indirectly received from money at interest upon any security or without security or from stocks or from any other investment, and whether such gains or profits are divided or distributed or not. ... [Page 451] Lord Bramwell, who was of the same opinion, said in part (pp. 394-5):— The appellants do not carry on a profession, trade, employment, or vocation from which profits or gains arise or accrue within the meaning of the Income Tax Act … I speak, of course, of the mutual insurance business. ... Solicitors for the appellant: Francis, Woods, Gauley & Blair. Solicitor for the respondent: F. ...

The Land Titles Act is presently R.S.S. 1940, chapter 98, and under section 2(1) thereof " 'certificate of title' means the certificate (Form A) granted by the registrar and entered and kept in the register". ... Esquimalt & Nanaimo Railway Company 48. This Court 49 had held the proposed imposts to be a tax in substance on the timber as and when [Page 251] severed, but that view was rejected. ... Solicitors for the Minister of Natural Resources and Industrial Development: Schumiatcher & McLeod. ...

Ce pourvoi présente une facette de la recherche par les contribuables de ce que le juge Bernier a appelé «... la façon de se pourvoir contre l’usage abusif de ces dispositions exorbitantes mais d’intérêt public, ou du pouvoir de perquisition et de saisie exercé en vertu d’une autorisation...». ... S’appuyant notamment sur un arrêt de la Cour d’appel de l’Ontario in re MNR v Paroian, Courey, Cohen & Houston, [1980] CTC 131; 80 DTC 6077 et sur un arrêt de la Cour d’appel de l’Alberta Royal Craft Products Ltd et al v MNR, [1980] CTC 97; 80 DTC 6143, le juge Dugas conclut: En somme, l’autorisation d’entrée et de perquisition appartient à une procédure d’investigation et non a une procédure d’accusation, ce qui devrait éliminer le besoin de nommer l’infraction reprochée. ... They were identified in the authorization in the present case — “for documents, books, records, papers or things pertaining or relating to Colla- vino Brothers Construction Company Limited that may afford evidence...” ...

The learned President rightly held that the case was within the principle of Mersey Dock & Harbour Board v. ...

Solicitors for the respondent: Holden, Murdoch, Walton, Finlay, Robinson & Pepall, Toronto. 1 [1960] Ex. ...

Attorneys for the respondent: Pinard, Pigeon, Paré & LeJour, Montreal. 1 [1962] Que. ...