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’ ’ Throughout the period mentioned there were three issued shares of Career Girl Store Limited (hereafter referred to as Career Girl) all of which were beneficially owned by Allied Business Supervisions Limited (hereafter referred to as Allied). ... But there was no question asking: ‘ ‘ Did beneficiaries of a trust ‘control’ or ‘have a controlling interest’ in the company?’’ ... In truth, the articles of association constitute a contract between the company and the shareholders which every shareholder is entitled to insist upon being carried out. ’ ’ That an article can restrict the right of a mere majority to bind the minority by an ordinary resolution appears from Quin & Axtens Ltd. et al. v. ...

Hollander & Sons Ltd. v. His Majesty the King, [1928-34] CTC 297, [1920-1940] DTC 275 MACLEAN P. ... The respondents, aS we have already observed, are not within s. 87 but, if they are a ‘producer’ or " manufacturer ‘ they are within s. 86.” ... If “transactions” means that the contract for the labour involved in dressing and dyeing the furs of customers was taxable as a sale against the dresser and dyer that would give to " " sale ” a meaning utterly foreign to the whole spirit of the Act; including even sec. 87(a), (b) and (d). ...

The Delta Glucose case was interpreting the words ‘ ‘ consumable materials ’ as they appeared in Schedule III to the Act at that time, but the words used in Schedule III in the period under consideration in the present case are ‘‘consumed or expended’’ which I consider to be broad enough to include the matrices which are discarded after one use. ... The fact that the matrices are subsequently ‘‘ ‘ consui^d or expended in the process of manufacture” of the rubber stamps as I have found does not alter the fact that before they are so consumed or expended they constitute ‘‘articles’’ rather than ‘‘materials’’. ... Armstrong & Co. Ltd. v. Deputy Minister of National Reve nue for Customs and Excise, [1967] 1 EX.C.R. 346; [1966] C.T.C. 778. 3 +R.S.C. 1927, c. 179. 4 * Judgment October 7, 1969. (1969), 23 D.T.C. 5372; [1969] C.T.C. 574. 5 *Canadian Sales Tax Reports 8561. 6 *Tariff Board Reports 1963-1966, p. 192. 7 ^Tariff Board Reports 1937-1956, p. 7. 8 tTariff Board Reports 1957-1962, p. 215. ...

Alpine Drywall & Decorating Ltd. v. Minister of National Revenue, [1966] CTC 359, 66 DTC 5263 CATTANACH, J. ... Alpine Drywall & Decorating Ltd. v. M.N.R., [1966] C.T.C. 359; Vineland Quarries & Crushed Stone Ltd. v. ... In view of the conclusion I reached in Vineland Quarries & Crushed Stone Limited v. ...

Joseph Simard & Cie, Ltee v. Minister of National Revenue, [1964] CTC 461, 64 DTC 5289 DUMOULIN, J. ... Simard & Cie Ltée, était une compagnie personnelle, l’entière propriété de Joseph Simard. ... André Piché, secrétaire de Foils Investment, en 1955 et antérieurement, spécifie que cette compagnie ‘‘.. est une ‘holding’ qui détient toutes les actions de Dominion Foils et que ne détient que ça dans son actif. ...

William $. Walker, [1951] CTC 334 HYNDMAN, D.J.:—These two appeals were heard together. ... Mallandaine, (1887) 18 Q.B.D. 276 at 277, Lord Denman said: "The words in 5 & 6 Vict. c. 35, s. 100, Sched. ... It will be noted that Lord Denman says ‘‘ ‘vocation’ is analogous to ‘calling.’ ”’ Other decisions which might be referred to are found in Gordon’s Digest, e.g., Trautwein v. ...

Campeau & Michael Petritz v. Minister of National Revenue, [1970] CTC 306, 70 DTC 6223 GIBSON, J. ... The relevant facts are as follows: The appellant Campeau was employed by and owned shares in two incorporated companies named Depco Metal Products Limited (herein called “Depco”) and Hercules Tool & Die Limited (herein called “Hercules”) and the appellant Petritz was employed by and owned shares in one only of the said incorporated companies, namely, Depco. ... London & West Riding Investments, Lid., [1967] 1 All E.R. 518 at 528; Littlewoods Mail Order Stores Ltd. v. ...

Shortt & Audrey Quinn v. M.N.R., [1960] CTC 78, 60 DTC 1056 THURLOW, J. ... Shortt, and the issue on which each case turns is whether or not the appellant is liable to pay the four per cent investment income surtax on the profits to which he or she was entitled of a business carried on under the name and style of James McTamney & Company. ... It is, I think, important to observe that, while the James McTamney & Company business was, by the will, vested in Maurice J. ...

The International Iron & Metal Co. Limited v. Minister of National Revenue, [1969] CTC 668, 69 DTC 5445 GIBSON, J. ... The voting shares of Burland Realty & Equipment Company Limited were held by the above group of persons and by one Sorie Rosenblatt. ... Goldblatt and Reuben Levy; that Burland Realty & Equipment Company Limited was controlled by the group of persons above set out in the respondent’s assumption and by Sorie Rosenblatt; and that as a consequence the appellant and Burland Realty & Equipment Company Limited were not associated corporations within the meaning of Section 39(4)* [2] of the Income Tax Act for the said taxation years. ...

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081 CAMERON, J. ... Secondly, a transaction which, on its true construction, is of a kind that would escape tax is not taxable on the ground that the same result could be brought about.by a transaction in another form which would attract tax. ’ ’ The question for determination, therefore, is ‘‘ What is the real character of the receipt?’’ ... C.I.R., 12 T.C. 1955, and similar cases. ’ ’ In the instant case, the appellant company retained the full ownership of its only capital asset—the Barclay Hotel. ...