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Nomad Sand & Gravel Ltd., [1991] 1 C.T.C. 60, 91 D.T.C. 5032 (F.C.A.) do not apply. ... In Nomad Sand & Gravel Ltd., supra, the nature of the taxpayer's business did not give the taxpayer any on-going connection with its customers that would have allowed the taxpayer to demonstrate it had to provide future services. ... At page 318 (D.T.C. 6164) of his judgment, Décary, J. stated: The question is whether the debts at issue were in fact acquired ”... for the purpose of gaining or producing income from a business or property....” ...

In February 1976 a senior officer of the Life Insurance Division of the Department of Insurance wrote to the Society about its practice in respect to financing its fraternal activities and advised in part "... it would be appropriate for the society to establish a separate and distinct fraternal fund", a practice said by the writer to be contemplated by the Canadian and British Insurance Companies Act, since it appeared from the Society's report that it had the “intent... to accumulate a substantial fund for fraternal purposes”. ... The reason for this was that the closing of our 1978 books was delayed when our tax advisors, Clarkson, Gordon & Co., surprised us with the news that Income Tax would not be payable from 1978 onward. ... I have requested that a tax specialist from Clarkson, Gordon & Co. be present at our meeting to explain this rather complicated procedure to the Board this morning. ...

Zhelka, [1967] 2 O.R. 565, 64 D.L.R. (2d) 457; Smith, Stone & Knight Ltd. v. ... Additionally, in Smith, Stone & Knight Ltd. v. Birmingham Corp., [1939] 4 All E.R. 116 (K.B.), Atkinson J. came to the conclusion that a parent company could sue the persons responsible for damage caused to one of its subsidiaries. ... At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles: "... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act and the intention of Parliament". ...

Support is found for this view, in the well-known passage from the judgment of Lord Diplock in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 518 at 528, reading as follows: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd and the defendants were a “sham”, it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...

There were 64,000 issued and outstanding common shares without par value of Amherst Quarries (1969) Limited, held as follows: $ H.M. ...

", he gave the following as the intent of the agreement: ”... I should not get any more than the $450,000 so that if I had received part of it by way of an interest free loan then that... amount should be considered for the payment of the management fee". [5] As the trial judge found, the interest-free loan advanced pursuant to Article 7.2 was linked to and was in reality part of the overall management fee arrangement in favour of the appellant. ...

McKean & Archibald Randolf, [1876] 16 N.B.R. 299; 3. M.N.R. v. Wardean Drilling Ltd., [1969] 2 Ex. ...

The respondent alleges in this case that the operations giving rise to the profits arose outside of Canada — specifically, the contract for the sale of the concentrate was negotiated in Lebanon and executed in the United States. ...

Article 6 Associates of Asamera (a) Asamera has the right to associate with it under this Agreement Plymouth Oil Company of Pittsburgh, Pennsylvania and/or Benedum-Trees Oil Company and/or Hiawatha Oil & Gas Company and/or any subsidiary (or successor of said companies acceptable to Asamera). ()b Asamera shall have the right to associate any other parties under this Agreement only with the express approval of Permina. ...

.”, and further must reasonably be regarded as “... having been received... in consideration or partial consideration...” for the covenants not to compete.* [1] The appellant, on the other hand, asserts that on the true construction of the material documents, particularly the notarial deed, the transaction in question was fundamentally a sale of assets: the shares and whatever other interests Louis and Harry had in the four companies, their rights to carry on a bakery business for 25 years, and their rights to the use of the name Richstone in any business (see clauses first, second, third and fourth of the notarial deed) for 25 years. ...