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Vide Societa Principessa lolanda Margherita di Savoia (fondata da Bonitesi), Inc. v. ...

While the same persons may control the two companies yet they are separate entities, and even the shareholders are not precisely the same; their respective business operations are really quite dis- tinct and were intended, I think, so to be. ...

In the appellant’s 1959 and 1960 taxation years now under review, the Minister did allow claims for reserves with respect to trading stamps sold by the appellant to other retail merchants, and the issuance of gift certificates and Christmas turkey certificates, in amounts he considered to be reasonable, but he dis- allowed the claims for the reserves with respect to the ‘‘Blue Chip Plan’’, the “Horizon Stamp Plan’’ and the ‘‘Save-a-Tape Plan’’ made by the appellant for those taxation years by notification under Section 58 of the Income Tax Act, dated July 30, 1964, on the particular ground that, ‘‘reserves for premium stamps and tapes supplied to customers claimed as deductions from income have been properly disallowed in accordance with the provisions of paragraph (e) of subsection (1) of Section 12 of the Act; that no part of the taxpayer’s receipts from customers represents an amount received in the year in the course of business that is on account of goods not delivered before the end of the year or that, for any other reason, may be regarded as not having been earned in the year or a previous year within the meaning of subparagraph (i) of paragraph (a) of subsection (1) of Section 85B of the Act and accordingly the taxpayer is not entitled to a reserve under paragraph (c) of the said subsection (1) of Section 85B.”’ ...

Next, on page 359, we read: et lorsque je dis que le locataire a droit à la possession si son bail a été précédemment enregistré, je ne veux pas reconnaître qu’il y ait un droit réel, un jus in re... ...

In my view the mortgages were purchased or obtained for the purposes of realizing the profits that would result from the dis- counts or bonuses within the short time the mortgages had to run to their maturity. ...

With reference to the appellant’s appeal against the assessment of the profits which it made from the acquisition and dis- position of certain vacant lands, it appears that the appellant, which was incorporated in 1949, did acquire certain revenue producing properties which, for the purposes of this appeal it may be assumed, were acquired for the purpose of obtaining a rental revenue from them and, in addition, in 1953, it started acquiring farm properties near the Côte-de-Liesse Road on Montreal Island, some of which properties were disposed of by it in a manner that is sufficiently indicated by a statement entitled ° Reconciliation of Net Profit Re Sale of Land’’, which is attached to the notice of appeal and which reads as follows: RECONCILIATION OF NET PROFIT RE SALE OF LAND RE: EXPROPRIATION BY THE FEDERAL GOVERNMENT— DEED 1106499 Date—Nov. 9/54 Expropriation Price $371,260.00 Cost of Land Sold—Purchased Oct. 21/52 $75,391,60 Cost of Land Sold—Purchased Oct. 31/52- 32,004.37 107,395.97 Net Profit_ $263,864.08 14 Time held re lot 525 as per deed 1106499—one year, 1 month and 28 days 44 Time held re lot 527 as per deed 1106499—one year, 2 months and 7 days RE SALE TO INNES EQUIPMENT LTD.— DEED 1109955 Date—Nov. 17/54 Selling Price — $ 50,180.20 Cost of Land Sold—Purchased Oct. 21/52 1- $ 5,206.23 Commission—Westmount Realties- 2,509.00 Notarial Fees 25.00 7,740.23 ” {.;: Net Profit — —- $. 42,439.97 Time held as per Deed 1109955—2 years, 27 days Lot 525! ...

In the case of registered owners of the Series “B” certificates. payment was made by the special cheque of the Trustee, which was headed “Trans-Canada Shares Series ‘B’—semi-annual dis tribution of income’’. ...

In the Knowles case the facts were that the directors of a limited company, which was not in liquidation, by resolution resolved upon the payment to the shareholders of (1) a dividend of 6d. per share; (2) a bonus of 6d. per share; and (3) "‘dis- tribution of assets 10s. per share,’’ which was paid out of accumulated profits. ...

Now if we turn to what is called the report of the operations and affairs of Massey-Harris Company Limited and subsidiary companies for the year ending on the 30th of November, 1929, appearing on the first page of the annual report for that year, we see, under the caption "‘Surplus account,” the following entries: "‘The surplus at 30th November, 1928, was $6,982,098.02 Less Bond Dis- count and Ex- pense_. $ 900,970.20 Less Premium on 7 % Preference Shares redeemed $1,100,770.00 $2,001,740.20 $4,980,357.82” This shows clearly that the amount of $10 per share paid on the 7% preferred shares, over and above their par value, came out of the so-called surplus account. ...

Roscoe, as at present in effect be free from income tax and subject to adjustment from time to time at the dis- cretion of the Managing Director, effective as from January 1st, 1941. ...