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The situation is almost identical to that considered in the case of Greig (Inspector of Taxes) v Ashton, [1956] 3 All ER 123 at 125, where Harman, J stated: The portion of the convention providing for double taxation relief with the United States appears in the Schedule to the Double Taxation Relief (Taxes on Income) (USA) Order, 1946 (SR & C 1946 Nc 1327), of which art XIII(2) provides: “Subject to such provisions... as may be enacted in the United Kingdom, United States tax payable in respect of income from sources within the United States shall be allowed as a credit against any United Kingdom tax payable in respect of that income.’’ ...

Another expedient to indicate a plurality of members would be to adopt a style such as: “Cornforth & Co” or “Cornforth and Associates”. ...

.: — Relief Requested This is an application by the Minister of National Revenue under subsection 174(1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

By Interpretation Bulletin IT-368 dated March 28, 1977 and entitled, “Corporate Distributions — Clearance Certificates” a wide application is given to subsections 159(2) and (3) by the Minister, Paragraphs 1, 2 and 3 of that Bulletin are those relevant in this matter. ...

In this connection Defendant refers to the judgment of the Court of Appeal in the as yet unreported case of The Clarkson Company Limited, the Receiver and Manager of the property and undertaking of Rapid Data Systems & Equipment Limited v Her Majesty The Queen, No A884-77 a judgment dated April 18, 1978, [1979] CTC 96. ...

The case therefore turns, as Addy, J put it in D P McLaws v The Queen, [1976] CTC 15 at 16: 76 DTC 6005 at 6006, “... entirely on the interpretation to be given to those facts and on the conclusions of fact to be drawn therefrom.. ...

.: — In 1978, François Prévost In (FPI) operated a real estate brokerage business in Québec. ...

On this see L Berman & Co Ltd v MNR, [1961] CTC 237; 61 DTC 1150, per Thorson, P at page 247 [1156]: There is no doubt in my mind that the appellant made the payments in question as a business person intending to continue in business would reasonably do and that consequently, they were made in accordance with the ordinary principles of commercial trading or well accepted principles of business practice and I am unable to find any ground in Section 12(1)(a) for their exclusion. ...

Lion Brewery Company Limited (1910), 5 T.C. 568 at 581: “ It is clear that it is not every expenditure which is made by a trader for the promotion of his trade, and which, in fact, contributes to the earning of profits, which is a permissible deduction from the estimate of profits for Income Tax purposes.” ...

That was the reasoning adopted by the Supreme Court of Canada in Steer, supra, and in Stewart & Morrison Ltd. v. ...