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Cosmopolitan Import & Export Limited was incorporated in 1946 but remained an inactive company until 1958. ... & Company Inc. and International Iron & Metal Co. Limited were enabled to enter into certain brokerage and commercial relationships which had not hitherto existed. ... I trust this reply gives you all the information you require. ’ ’ On these facts, I am of opinion that Cosmopolitan Import & Export Limited was ‘‘activated’’ for the express purpose of receiving the commissions from Luria Bros., Inc. and that, during the material times, it was not actively engaged in a business, except incidentally, which had nothing to do with the earning of the commissions, the subject matter of this appeal. ...

On March 10, 1947, the Minister of Lands and Forests forwarded a letter to the appellant (Exhibit 3) in these terms: ‘ ‘ For your information I am enclosing a copy of the ‘ Manual of Requirements for Working or Management Plans, Operating Plans, Annual Cutting Applications and Forest Surveys’. ... In the case of Strong & Co. v. Woodsfield, [1906] A.C. 448 at 453, Lord Davey said: ‘6.. ... M.N.R., [1944] A.C. 126 at 133, where Lord Macmillan, in the Judicial Committee of the Privy Council, said: “... ...

In these appeals, as in the appeals of Alpine Dry wall & Decorating Ltd., the sole question is whether the appellant is associated with Jager Holdings (Calgary) Limited within the meaning of the word ‘‘associated’’ as used in Section 39 of the Income Tax Act. ... In view of the conclusion I reached in Vineland Quarries & Crushed Stone Limited v. ... For the reasons expressed in the appeals of Alpine Drywall & Decorating Ltd., which are being filed concurrently herewith, I must conclude that it does not. ...

M. le juge Locke, parlant pour la Cour, dans la cause Sutton Lumber & Trading Co. ... For the following years, the dates of the original assessments, re-assessments, notices of objection and notifications in reply are as follows: Taxation Dates Notice of years Assessment Re-assessment Objection reply 1951 May 15,1952 Aug. 14,1956 Sept. 5,1956 June 17, 1957 1952 June 3, 1953 «6 66 cc 66 “ 66 66 «6 66 1953 ‘6 4,1954 “ 66 66 u u é6 66 u rT 1954 “ 17,1955 cc « 6 CR u «ec ‘kk ce In 1956, the Minister re-assessed the appellant under the provisions of Section 42 of The 1948 Income Tax Act for the taxation years involved. ... M.N.R., [1954] C.T.C. 367, the President of this Court stated at page 373: “... ...

They explained the intention of the decedent in setting up the so-called The Harshman Foundation ’ namely, that he was interested in assisting students of need who might with financial assistance in their education be able to take their place in Canadian society in a more substantial way and that in so assisting such persons through the Foundation, that in some measure the so-called brain drain ’ ’ to the United States might be abridged. ... The appellant in argument, submitted that “The Harshman Foundation ’ ’ was not an inter vivos or testamentary trust in the same way as was held in M.N.R. v. ... Section 7(1) (d) of the Estate Tax Act, as amended in 1960, substantially enlarged the number of organizations in Canada to which inter vivos or testamentary gifts could be made which would qualify for deductions for the purpose of computing the aggregate taxable value of property passing on the death of a deceased donor for the purposes of estate tax by the addition of the words ‘‘or to the making of gifts to other such organizations in Canada all or substantially all of the resources of which were so devoted ’ ’. ...

La personne qui reçoit l’allocation doit l’affecter exclusivement 2‘1 l’entretien, au soin, 2‘1 la formation, 2‘1 l’instruction et 2‘1 l’avancement de l’enfant, et, si le Ministre, ou le fonctionnaire que les règlements autorisent à cet égard, est convaincu que l’allocation n’est pas ainsi affectée, le versement en doit être discontinué ou fait à quelque autre personne ou organisme. ’ ’ S.R.C. 1946, 10 Geo. ... Les griefs de l’appelant à l’égard de ces dispositions législatives sont résumés à l’article 6 de l’avis d’appel; je pense qu’il suffira de reproduire ce raccourci pour en donner une idée juste: ‘ 66. ... L’article 91 de la constitution de 1867 édicte que: ‘ ‘... l’autorité législative exclusive du Parlement du Canada l’étend à toutes les matières tombant dans les catégories de sujets ci-dessous énumérés... 3. ...

Asked if he considered the asset, appearing in Adam & Co. Inc., of the notes of Angus Corporation, Adam replied negatively and supplied this information (p. 16): " " A. ... I would consider the financial position of the maker of the notes as at the date of death. ’ ’ Kent admitted that he had before him the balance sheets of Adam & Co. ... It was a loan on the same terms to Adams & Co. Ine. as Grampian loaned the Money to Adam & Co. ...

At page 7, he said: " " The question is whether this is a loss incurred by the taxpayer in the production of his income. ... At page 260, he said: " " Now in this particular case we have come to the conclusion on the evidence, that damage or loss of this kind must be regarded as incidental to the business of stevedoring. ... I think the disbursements are such as are made for that purpose. ’ ’ What is meant is that the disbursement must be made for the purpose of enabling a person to earn the profits in the trade. ...

The amounts of the several items of expense just mentioned are not in dispute. (1) Premium paid upon retirement of the issue of old bonds $1,104,600.00 (2) Exchange premium paid upon retirement of the issue of old bonds 676,726.00 (3) Expenses in connection with the retirement of the issue of old bonds 25,793.42 (4) Discount on the issue of new bonds: $ 5,000,000 par value at 114 per cent $ 75,000 $10,000,000 " " 4 11 " 400,000 475,000.00 Total $2,282,079.42 I perhaps should here add by way of explanation that there was a provision in the trust deed securing the old bond issue which required the payment of a premium of 4% in the event of redemption before maturity. ... I might point out here that in Canada, under s. 5 (&) of the Act, such reasonable rate of interest on borrowed capital used in the business to earn the income as the Minister in his discretion may allow is permissible as a deduction, and the appellant, in the period in question was allowed a deduction on this account. ... It therefore seems to me to be difficult to say otherwise than that all expenses in question here constituted an outlay on account of capital, within the meaning of the statute, even though on equitable grounds the appellant’s view seems attractive and in many ways quite just, In the case of Archibald Thomson, Black & Co. v. ...

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