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In biscuit form it is not a ‘‘ bakers’ biscuit’’. In powder form it is not a base or concentrate for making a food beverage. ... It is true that the Tariff Board when it held that ‘‘ Metrecal Powder’’ was subject to tax said that it was a pharmaceutical. ... Metrecal Liquid: The respondent seeks exemption for this product on the ground that it comes under the category ‘‘ Drinks prepared from milk or eggs” for which an exemption is provided by Schedule III. ...

Of these 15 per cent * " cashed-up ” as the result of the inducements held out, 20.5 per cent were good paying accounts requiring only from 1 to 4 dunning letters, 20 per cent required from 5 to 9 letters, 18.5 per cent from 10 to 20 letters, 16.5 per cent from 21 to 29 letters and 9.5 per cent 30 letters and over. ... C'.I.R. (1927), 11 T.C. 590 at 595, that, " " receivability without receipt for the purpose of Income Tax is nothing at all”: Vide also Dewar v. ... Smail’s work on Accounting Principles and Practice: "‘Income is realized just as fully when an asset is sold for a promise of cash as when it is sold for cash down. ’ ’ Mr. ...

To determine this, it is necessary to examine the facts with care. ’ ’ Similarly, Lord Warrington of Clyffe, in the case of Salisbury House Estate, Ltd. v. ... It was pointed out in the judgment of the Lord President at p. 215 that: ‘ The purpose which informed the Company was to salve something from the wreck of a type of trading enterprise which when the Company was formed was not ‘dormant’ but dead, by selling the separate flats in the only possible fashion for the benefit of the firm’s creditors and of the beneficiaries of the estates of the deceased partners.’’ ...

Their shareholdings in that company were in these proportions: Conn Smythe 52% Conn Stafford Smythe 30.8 % Clarence H. ... There is only one possible conclusion from an examination of * these artificial transactions and that must be that their purpose was to distribute or appropriate to the shareholders the “undistributed income on hand’? ... What was done with the business of the Security Com- ‘ pany fell somewhere within the meaning and spirit of those words. ...

. … (6) The Corporation and its hospital shall maintain at the said hospital such staff as may be required by the Commission for the purpose of rendering adequate medical care and treatment to its patients. ... Solicitors for the respondent: Fraser & Beatty, Toronto.   [1] [1979] 2 F.C. 786. [2] [1974] 2 F.C. 658. [3] [1965] 1 Ex. ...

.), c. 75, which Act was confirmed by An Act respecting Bathurst Paper Limited — Les Papeteries Bathurst Limitée, 1966 (N.B.), c. 124. ... A narrow point of statutory construction is involved by reason of a claimed exemption from tax under An Act relating to Bathurst Company, Limited, 1927 (N.B.), c. 75, as confirmed by An Act respecting Bathurst Paper Limited — Les Papeteries Bathurst Limitée, 1966 (N.B.), c. 124, deemed by its terms to have come into force on March 31, 1965. ...   [1] (1970), 2 N.B.R. (2d) 514, 15 D.L.R. (3d) 468. ...

The description of the property, as contained in the notarial deed of sale, included the statement: ‘““AVEC bâtisses dessus érigées, portant les numéros civiques 4474 et 4477 du dit Boulevard Sir Wilfrid Laurier, et toutes dépendances y attachées. ’ ’ Formal conveyance of the immovable property and the shares was made pursuant to an option contained in a letter dated August 3, 1962 which reads: Montréal, le 3 aout 1962 Monsieur Marc Masson Bienvenu, 210 ouest rue St-Jacques, Montréal, P.Q. ... Ltd. me seront rem boursées: $ 56,869 somme totale que je devrait recevoir par chèque visé $650,000 Lors de la clôture de cette transaction, je conviens d’acheter de La Maison Bienvenu Limitée et de payer par chèque visé, 12,500 actions de Corporation d’Expansion Financière un prix de $20.00 chacune, soit $250,000. ...

(all concur): — Two applications have been made by the Deputy Attorney-General of Canada (hereinafter referred to as ‘‘the applicant’’) for leave to appeal to this Court, pursuant to Section 41 of the Supreme Court Act. ... The relevant provisions of Section 126A are as follows: “126A. (1) In this section (b) ‘custodian’ means a person in whose custody a package is placed pursuant to subsection (3); (e) ‘solicitor-client privilege’ means the right, if any, that a person has in a superior court in the province where the matter arises to refuse to disclose an oral or documentary communication on the ground that the communication is one passing between him and his lawyer in professional confidence. (3) Where an officer is about to examine or seize a document in the possession of a lawyer and the lawyer claims that a named client of his has a solicitor-client privilege in respect of that document, the officer shall, without examining or making copies of the document, (a) seize the document and place it, together with any other document in respect of which the lawyer at the same time makes the same claim on behalf of the same client, in a package and suitably seal and identify the package; and (b) place the package in the custody of the sheriff of the district or county in which the seizure was made or, if the officer and the lawyer agree in writing upon a person to act as custodian, in the custody of such person. (4) Where a document has been seized and placed in custody under subsection (3), the client, or the lawyer on behalf of the client, may (a) within 14 days from the day the document was so placed in custody, apply, upon 8 days’ notice of motion to the Deputy Attorney General of Canada, to a judge for an order (i) fixing a day (not later than 21 days after the date of the order) and place for the determination of the question whether the client has a solicitor-client privilege in respect of the document, and (ii) requiring the custodian to produce the document to the judge at that time and place; (b) serve a copy of the order on the Deputy Attorney General of Canada and the custodian within 6 days of the day on which it was made, and, within the same time, pay to the custodian the estimated expenses of transporting the document to and from the place of hearing and of safeguarding it; and (c) if he has proceeded as authorized by paragraph (b), apply, at the appointed time and place, for an order determining the question. (5) An application under paragraph (c) of subsection (4) shall be heard in camera, and on the application (a) the Judge may, if he considers it necessary to determine the question, inspect the document and, if he does so, he shall ensure that it is repackaged and resealed; and (b) the judge shall decide the matter summarily and, (i) if he is of opinion that the client has a solicitorclient privilege in respect of the document, shall order the custodian to deliver the document to the lawyer, and (ii) if he is of opinion that the client does not have a solicitor-client privilege in respect of the document, shall order the custodian to deliver the document to the officer or some other person designated by the Deputy Minister of National Revenue for Taxation, and he shall, at the same time, deliver concise reasons in which he shall describe the nature of the document without divulging the details thereof. (7) The custodian shall (a) deliver the document to the lawyer (i) in accordance with a consent executed by the officer or by or on behalf of the Deputy Attorney General of Canada or the Deputy Minister of National Revenue for Taxation, or (ii) in accordance with an order of a judge under this section; or (b) deliver the document to the officer or some other person designated by the Deputy Minister of National Revenue for Taxation (i) in accordance with a consent executed by the lawyer or the client, or (ii) in accordance with an order of a judge under this section. (11) The custodian shall not deliver a document to any person except. in accordance with an order of a judge or a consent under this section or except to any officer or servant of the custodian for the purposes of safeguarding the document. (14) Where a lawyer has, for the purpose of subsection (2) or (3), made a claim that a named client of his has a solicitorclient privilege in respect of information or a document, he shall at the same time communicate to the Minister or some person duly authorized to act for the Minister the address of the client last known to him so that the Minister may endeavour to advise the client of the claim of privilege that has been made on his behalf and may thereby afford him an opportunity, if it is practicable within the time limited by this section, of waiving the claim of privilege before the matter comes on to be decided by a judge or other tribunal. ’ ’ I agree with the view expressed by Lord, J.A., in the Court of Appeal, that, in cases to which the section is applicable, 4 Section 126A is a complete code in itself for deciding the question of solicitor-client privilege relative to documents of a client in the possession of a solicitor.” ...

In paragraph 16 the testator directed that out of the ‘‘ general income’’ of his estate, including ‘‘the net annual income properly divisible as profits” derived from the Telegram business, there should be paid certain annuities, including annuities in favour of his wife and his two sons and the Hospital for Sick Children. ... Smyrna & Cassaba Ry., [1895] 2 Ch. 596, to which the appellants also refer, where the decision in Bridgewater was followed, an investment made by the defendant company having fallen in value in the market, the amount of the depreciation was debited to revenue. ... I take that to mean that once each year when the i ‘ net annual income properly divisible as profits’’ derived from the business has been transferred to the general income account of the trustees, the latter, under the article, have no further interest in the income of the business for that year; and that it is only the residue of that general income remaining after payment of the specific bequests that is directed to be accumulated for the beneficiary mentioned in the last paragraph of the article. ...

But, moreover, it is not " all professions’’ that can claim the exemption. ... On that point the section enacts: “In any case the decision of the Minister shall be final and conclusive. ’ In this case, the decision of the Minister is to that effect. ... I do not think that the words ‘‘business’’ or "" calling” are used in the section as terms of art intended to define mutually exclusive categories of sources of income but in the popular and ordinary sense and, so used, I think that the words ‘‘profits derived from a commercial or financial or other business’’ are wide enough to include the earnings of a commercial traveller. ...