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Joseph $. Irwin v. Minister of National Revenue, [1962] CTC 572 Noel, J. ... Ch. 748, to the effect that the word ‘ from ’ ’ may mean either inclusive or exclusive accord- ing to the context and subject matter and Canadian Fina Oil Limited v. ... Justice Day stated: “... as regards time, the word ‘from’ is akin to ‘after’ and excludes the day fixed for commencement of the computation. ’ ’ In Brown v. ...

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221 THURLOW, J. ... C.R. 234 at 241; [1961] C.T.C. 45 at 53. 9 + Vide Lord Macmillan in Stag Line Ltd. v. Foscolo, Mango & Co., [1982] A.C. 328 at 350. 10 [1963] S.C.R. 131; [1963] C.T.C. 51. 11 * The problem is described as follows in a note by Arnold D. ...

Stewart & Morrison Limited, [1970] CTC 431, [1970] DTC 6295 KERR, J. ... The so-called New York office was Stewart & Morrison Inc. a wholly owned subsidiary of the respondent. ... The letter states: In response to your request we are pleased to submit below a record of amounts received by Stewart & Morrison, Inc. from Stewart & Morrison Limited as capital contributions and loans payable. ...

Army & Navy Department Store Limited v. Minister of National Revenue, [1952] CTC 273, 52 DTC 1169, [1952] DTC 1168 ARCHIBALD, J. ... This statement is as follows: ‘ ‘ There are three companies involved in these proceedings, namely, Army & Navy Department Store (Western) Limited (hereinafter referred to as the ‘Western company’); Army & Navy Department Store Limited (hereinafter referred to as the ‘Alberta company’) and Army & Navy Department Store Limited (hereinafter referred to as the ‘Saskatchewan company’). ... Cohen) (2) The Alberta company—the shareholders are— 50 % to H. R. Cohen 10% to S. ...

& R. Weir, Limited v. Minister of National Revenue, [1964] CTC 529 DUMOULIN, J. ... " The witness admits these particular operations were not transacted on the open market but through private contracts. ... So far, so good, but, then, whose bonds attracted that ‘ ‘ natural increment”? ...

Stewart & Company Limited v. Minister of National Revenue, [1946] CTC 311 0 ‘CONNOR, J. ... In 1927 see. 10 of this Act read: " 19. On the winding up, discontinuance or reorganization of the business of any incorporated company, the distribution in any form of the property of the company shall be deemed to be the payment of a dividend to the extent that the company has on hand undistributed income.’’ ... Failure to pay the tax within the prescribed time shall render the company liable for interest thereon at that rate of six per centum per annum until paid. ‘ ‘ In 1934 see. 19 was amended by striking out the words "‘in the taxation period 1930 and subsequent periods’’, leaving the section as it stood in 1927. ...

Jacob Mayer & Sons Ltd. v. Minister of National Revenue, [1954] CTC 141, 54 DTC 1075 THORSON, P. ... Mayer & Sons. The business was entirely his and he owned all its assets. ... Mayer & Sons. A meeting of the directors followed immediately afterwards. ...

& S. duty September 10, 1957, $1,600.00, making a total of $5,067.42; March 31, 1956, to United China & Glass, $2,620.35, plus Canada S.S. Lines $219.23, plus Samson & Shaen, $1,302.61, making a total of $4,142.19; and June 6, 1956, to Shore & Coggins, $998.75. ... Wild, $1,570.09; and on July 6, 1956, to Shore & Coggins, $998.75. ...

Miron & Frères Limitée v. Minister of National Revenue, [1954] CTC 45, 54 DTC 1022 Fournier, J. ... Michel for the price of $90,000.00 and in 1949 he sold this property to Miron & Frères Limitée for the price of $600,000.00. ... The dispute between the parties is on the interpretation to be given to the words " " a corporation and one of several persons by whom it is directly or indirectly controlled shall be deemed not to deal at arm’s length’’. ...

O’reilly & Belanger, Limited v. Minister of National Revenue, [1917-27] CTC 332, [1920-1940] DTC 121 AUDETTE, J. ... & of sec. 3 of the Act which reads as follows: "" (8) In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of:— "(a) disbursements or expenses not wholly, exclusively and necessarily laid out or expended for the purpose of earning the income. ” These provisions of the statute, like those of the English Act. do not affirmatively state what disbursements and expenses may, be deducted, and there is in words no deductions allowed at ail unless indirectly. ... This argument, he says, would require the words *‘ wholly and exclusively’’ to read "’wholly, exclusively and necessarily”: that is the very wording of the Canadian Statute. ...