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V, c. 46), by sec. 8 of the same Act was " " deemed to be applicable to the income for the taxation period 1921 and subsequent periods.” and the appellant contends that the part of the accumulated profits earned before that date is not subject to such taxation, and moreover contends, in the alternative that the whole of that sum is capital and not subject to taxation. ... V, ¢. 46) is that dividends made up of undistributed profits and paid or payable after 1921 as under the circumstances of the case, are liable to tax. ... V, €. 55) passed in 1919 and hereabove recited, declaring that dividends are taxable as income of shareholders in the year in which the same are received or credited. ...

There never has been, and I think there never will be, much difficulty in dealing with any particular case on its own facts and circumstances; and, speaking for myself, I rather doubt the wisdom of attempting to do more.’ ‘‘ In Montreal Coke and Manufacturing Co. v. ... Lord MacMillan said at page 100:— " " Expenditure to be deductible must be directly related to the earning of income. ... The statute in see. 5(b) above quoted significantly employs the expression ‘ capital used in the business to earn the income’, differentiating between the provision of capital and the process of earning profits. ’ ’ In this case the company is not engaged in financial operations but is engaged in the construction business. ...

Bag 63 63 35 Monarch Quarters 42 35 — Moms Regular 63 63 35 Moms Quick Bag 63 63 35 Moms Squares 63 63 35 Golden Girl 42 35 35 Golden Girl Cartons.. 42 35 35 Golden Girl Quick Bag 42 35 35 Silverdale Squares.... 63 63 35 Buttercup 63 63 35 Top Value Regular.... 63 63 35 Top Value Quick Bag 63 63 35 Top Value Squares.... 35 Monarch Regular 42 35 — JAYMAX 63 63 35 Moms Family Pack.... 63 63 35 Discount Margarine.. 63 63 35 Golden Gal Squares.. 63 63 35 Monarch Squares 35 — Blue Band 63 63 35 17. ... The term ‘‘marine oil’’ is used to describe the oils so derived, presumably because whales and seals are not truly fish but marine creatures but in any event the terms ‘ marine oil ’ ’ and ‘ ‘ fish oil ’ ’ are used interchangeably in the industry. ... I do not think that, in common parlance, the words ‘‘ product of fish’’ can be considered as comprehending margarine, even though it contains fish oil as one of its principal ingredients. ...

Lord Buckmaster after stating "‘most unhesitatingly’’ that the grant was not a trade receipt, went on to say, at page 353: " " It appears to me that it was nothing whatever of the kind. ... That purpose was a special one, namely, " " for assistance in carrying out approved schemes of useful work to relieve unemployment.’’ ... I do not think that was the effect. ‘ ‘ Similar remarks would be appropriate in the present case. ...

In addition to any writs of execution that are prescribed by general rules or orders, the Court may issue writs of execution against the person or the goods, lands or other property of any party, of the same tenor and effect as those that may be issued out of any of the superior courts of the province in which any judgment or order is to be executed; and where, by the law of the province, an order of a judge is required for the issue of any writ of execution, a judge of the court may make a similar order, as regards like executions to issue out of the court. ’ ’ Procedure by writ of garnishment (saisie-arrêt) of the kind issued in this case is a method of attaching and realizing upon debts owing to a judgment debtor which is provided for in the Province of Quebec by Articles 677 et seq. of the Quebec Code of Civil Procedure. ... The rules concerning the service of ordinary writs of summons apply to seizures by garnishment. ’ ’ Reference may also be made to Articles 127, 128 and 142 by which it is provided that: “Art. 127. ... In default of the said garnishee (Tiers Saisi) and defendant to appear and by the said garnishee to make the declaration and to comply with the injunctions above mentioned the said garnishee (Tiers Saisi) may be adjudged by default to pay the debt, interest and costs remaining due as aforesaid and also the costs of the present instance to which costs the defendant will be condemned each time that an effective attachment does not suffice to discharge all that he owes. ’ ’ The point taken was that grammatically read this writ did not call upon Canadian Javelin Limited to show cause why the seizure would not be declared valid and that accordingly the writ did not comply with the requirements of Article 678. ...

This information, however, was insufficient to meet the requirements of the regulations; it was necessary, therefore, to secure further and up-to-date information as to the inventory of timber before the required " " estimated inventory’’, the Master Plan for managing the timber area, and the Map could be furnished to the Minister. ... I prepared them (i.e., the cruise regulations) to satisfy the conditions of that manual. ‘ ‘ Mr. ... In the case of Strong & Co. v. Woodifield, [1906] A.C. 448 at 453, Lord Davey said:. ...

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. ...

Strachan 666 102 2.17 — — C. A. Ebner — — — 3,231 33 17.0 W. E. Jacobson 333 81 11.7 1,425 14 7.5 3,000 549 100% 19,008 190 100% The respondent in its assessment assumed that the appellant and Canadian Mouldings Limited were both at some time in the taxation year 1961 controlled by the following group of persons in Schedule “D” hereunder, which comprises all the shareholders of both corporations who are common to both companies and therefore excepting therefrom A. Strachan who holds shares in Canadian: Mouldings Limited only and. ©, A. ... LIMITED CANADA LIMITED Common Preferred Common Preferred Shareholder_ Shares Shares % Shares Shares % F. ...

Section 58 of the Act, prior to its amendment in 1944, read as follows: " " 58. ... Then section 66 provides: " *66. Subject to the provisions of this Act, the Exchequer Court shall have exclusive jurisdiction to hear and determine all questions that may arise in connection with any assessment made under this Act etc. ’ ’ This language is, I think, clearly wide enough to cover questions affecting the validity or correctness of the assessment and any complaint the appellant may allege or have against it. ... The use of the word ‘ ‘ allow ‘ ‘ in the section connotes that there is a claim before the Minister for his consideration. ...

The accounting for sales of topsoil was left to the owner of Circle ‘ ‘ J ’ ’ Ranches Ltd. and difficulties were experienced in obtaining satisfactory accounts and credits. ... Add: 25% corner influence $ 27,273. $ 516.354. ($36.00 sf) on 40’ (2) 179'4" x 80’ = 14,350 sf at $2,180. ff or $27.27 sf $391,264. Add: 25% corner influence $ 21,818. $ 413,082. ($28.80 sf) on 40' (3) 76'6%" X 100’ = 7,656 sf at $1,820. ff or $18.18 sf $139,200. ...