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Ralston & Co., 96 DTC 6488, [1996] 3 CTC 346 (FCTD) Pinard J.: — This is an appeal by way of action against a judgment of the Tax Review Board (the “Board”) dated February 8, 1982, 82 D.T.C. 1128 (T.R.B.), which allowed the defendant’s appeal against reassessments for income tax dated April 30, 1976 with respect to the defendant’s 1970, 1971, 1972, 1973 and 1974 taxation years. ... Ralston &. Co. Technical Holdings Technical Canada Products Tape Lid. ... Martel & P. Martel, La compagnie au Québec, vol. 1 (Montréal: Éditions Wilson & Lafleur Ltée, 1992) (“Martel”) state: Le premier droit conféré l’actionnaire est celui de l’égalité de traitement. ...

They may be summarized as follows: — between March 24, 1992 and February 1, 1993, the respondent imported air diffusers into Canada; — the imported air diffusers were made of plastic and were designed as an attachment to hair dryers; — at the time of each importation, the air diffusers were classified under Tariff item No. 3926.90.90 of Schedule I to the Customs Tariff [3] as “other articles of plastics”; — the respondent urged that the air diffusers should be classified under Tariff item No. 8516.31.10 as parts of domestic hair dryers and therefore requested, pursuant to paragraph 60(l)(b) of the Customs Act, a re-determination of the tariff classification of the air diffusers. It was determined that the imported goods were properly classified under Tariff item No. 3926.90.90 as other articles of plastics; — the respondent subsequently requested a further re-determination of the tariff classification of the air diffusers by the Deputy Minister of National Revenue for Customs and Excise pursuant to paragraph 63(l)(a) of the Customs Act; — on August 26, 1993, the appellant confirmed the classification of the air diffusers under Tariff item No. 3926.90.90; — on September 15, 1993, the respondent appealed the decision to the Tribunal pursuant to section 67 of the Customs Act; — by the decision here under appeal, the Tribunal found in favour of the respondent; — the parties are in agreement that the classification of goods under Schedule I to the Customs Tariff is to be governed by the Generpal Rules for the Interpretation of the Harmonized System and the Canadian Rules and the Explanatory Notes to the Harmonized Commodity Description and Coding System. ... Deputy Minister of National Revenue (Customs & Excise) [7] ', a classification matter before the Tribunal dealing with television converters, the Tribunal, in concluding that television converters were parts to television receivers, wrote: Although the television can operate without a converter by increasing the number of channels a television is capable of receiving, a converter contributes directly to the main function of a television receiver, that being the reception of audio-visual signals. ...

In 1971 the defendant paid $75,000 to Stan Fowler Insurance Agencies Limited (hereinafter referred to as the ‘‘Fowler Agency’’) and another $53,000 to a firm of solicitors, namely, Stirling, Ryan, Goodridge, Caule, Guchus & Goodridge (hereinafter referred to as “Stirling & Ryan’’) both of St John’s Newfoundland. ... In so far as Stirling & Ryan were concerned, they had developed, in conjunction with their law practice, an insurance portfolio of some 870 insurance client files. ... On the same day, that is, May 28, 1971, a letter of acceptance of the offer was sent by Stirling & Ryan to the defendant accepting the offer of $53,000 mentioned in the letter of May 17. ...

Hughes & Co. Holdings Ltd., 94 DTC 6511, [1994] 2 CTC 170 Muldoon J. ... Hughes himself did not assert — was 101 hours, similarly rounded up to 105 hours. ... Dictionary of Canadian Law, Dukelow & Nuse, Carswell: FULL-TIME BASIS. ...

Thames Bandag & Tire Ltd. v. The Queen, 88 DTC 6417, [1988] 2 CTC 203 (FCTD) Martin, J. ... THAMES BANDAG AND TIRE LIMITED per C/S President THAMES TIRE & AUTO CENTRE (LONDON) INC. per C/S The address of Thames Bandag and Tire Limited and Thames Tire & Auto Centre (London) Inc. is 563 Clarke Road, London, Ontario. ... As a result of the demand by the Royal Bank Thames Bandag and Tire Limited and Thames Tire & Auto Centre (London) Inc. ...

Her Majesty the Queen, Creditor — v. Harold Wayne Mullins, [1985] 2 CTC 128 Le juge Denault:—Le 18 décembre 1984, le juge Rouleau a accordé une requête pour ordonnance provisoire de constitution de charge immobilière, en vertu de la Règle 2400 des Règles de la Cour fédérale dans les termes suivants: IT IS ORDERED that unless sufficient cause to the contrary be shown before the Court, sitting in Montreal at 1 Notre-Dame Street East on the 25th day of January, 1985 at 10:00 am, that a one half undivided interest in the undivided half (or a one quarter undivided interest) of the said immoveable shall stand charged with the payment of $17,583.56 remaining due on said certificate as well as the supplementary interest at the annual rate provided for time to time by section 161(1) of the Income Tax Act on the sum of $10,307.60 as of the 2nd day of August 1984 until the date of complete payment together with the costs of this application and it is further ordered that said charge subsists until the hearing of aforesaid reasons. ... Le juge Marceau, dans l'affaire Couillard * [1] s'exprimait ainsi dans une affaire semblable: Il ne s’agit pas ici d’une saisie-exécution immobilière, mais l’ordonnance de constitution de charge recherchée aura une portée plus grande que n’en a l’enregistrement d’une hypothèque judiciaire comme le prévoit le Code civil de la province de Québec (art 2034 et s et art 2121 cc). ... Ainsi donc, en se prévalant de la Règle 2400, la créancière ne procède pas immédiatement à la saisie de l'immeuble — elle pourra le faire éventuellement — mais elle veut le grever de l'équivalent d'une hypothèque judiciaire pour assurer la protection de ses droits. ...

Canada (Minister of Citizenship & Immigration), [1998] 4 CTC 86 Simpson, J.: The Applicant seeks judicial review of a decision of an Immigration Officer (the “Officer”) dated January 27, 1998, wherein the Officer decided there were insufficient humanitarian and compassionate (“H & C”) considerations to recommend a favourable decision under Section 114(2) of the Immigration Act, R.S.C. 1985, c. ... The Applicant filed his H & C application under Section 114 of the Act in March 1997 (the “Application”). ... It is for the Applicant to place all pertinent information before the Officer on an H & C review. ...

H a Fawcett & Son, Limited v. Her Majesty the Queen, [1979] CTC 303, 79 DTC 5224 Dubé, J:—The main issue to be determined in this case is whether the plaintiff corporation in its fiscal year ending November 30, 1975 was associated with Fawcett Enterprises Limited and Son Valley Ranch Limited under paragraph 256(1)(b) of the Income Tax Act on the basis that all three corporations are controlled by the same person, George C Fawcett. ... If it had been the intention of Parliament to exclude from the provisions of paragraph 256(1)(b) shares which were acquired by an executor or a trustee by virtue of the death of any other person it would have done so in clear unambiguous terms, as it did for the purposes of other subsections.* [5] The appeal therefore should be dismissed with costs. 1 Judson, J in MNR v Consolidated Holding Co, [1974] S.C.R. 419 at 423; [1972] CTC 18 at 20; 72 DTC 6007 at 6008. 2 T Thurlow, J (now ACJ) in Career Girl Store v MNR, [1967] 1 Ex CR 21; [1966] CTC 330; 66 DTC 5244. 3 + Vineland Quarries & Crushed Stone v MNR, [1966] Ex CR 417, 429; [1966] CTC 69; 66 DTC 5092. The reasons and conclusions of Cattanach, J were adopted by the SCC—see 67 DTC 5283 at 5284. 4 § Buckerfield’s Limited v MNR, [1965] 1 Ex CR 299, at 305; [1964] CTC 504 at 509; 64 DTC 5301 at 5304. 5 See subparagraph 256(7)(a)(ii) added by SC 1977-78 c 1, section 99, which reads (7) Where control deemed not to have been acquired. ...

There was no evidence for the plaintiff and one witness for the defendant, John Charles Meuller, chief financial officer of the defendant Marsh & McLennan, Limited. the defendants Harry Price and Hillborn Insurance Limited in related action number T-3556-79, are wholly-owned subsidiaries of Marsh & McLennan, Limited, so that evidence and argument and judgment in this matter apply equally to them. ... I am conscious that the Company likely would not have been overjoyed at such a result, and obviously chose a normal course — to obtain maximum revenue. ... In my view, the conclusions of the Board in the March Shipping matter were entirely valid and were properly relied upon in deciding the Marsh & McLennan matter as it did. ...

Silver Creek Cedarwood Total CMHC mortgage insurance $ 79,300 $ 66,536 $ 145,836 fee CMHC mortgage application 7,350 7,735 15,085 fee Interest during construction 1,493,823 1,217,282 2,711,105 and lease-up Mortgage guarantee fee 80,291 67,368 147,659 Mortgage brokerage fee 64,233 53,894 118,127 Legal Fees relating to mort 25,000 25,000 50,000 gage financing and other doc umentation Landscaping 100,000 50,000 150,000 Administration and leasing 362,000 243,300 605,300 services Cash flow guarantee 171,525 145,349 316,874 $2,383,522 $1,876,464 $4,259,986 7. ... The Supreme Court of Canada has recently set out the following principles, to be applied on a case-by-case basis, to the computation of profit under ss. 9 & 12 of the Act: Canderel Ltd. v. ... & Minister of National Revenue v. Colford Contracting Co. (1960), 60 D.T.C. 1131 (Can. ...