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Counsel added that this interpretation was supported by the text services, or classes, grades or qualities thereof, the amount that may be deducted under this section is an amount equal to the lesser... (4) For the purposes of this section, (a) ‘allocation in proportion to patronage' for a taxation year means an amount credited by a taxpayer to a customer of that year... computed at a rate in relation to the quantity, quality or value of the goods or products... sold... to the customer... with appropriate differences in the rate for different classes, grades or qualities thereof... ” of the definition of the phrase “allocation in proportion to patronage” found in paragraph 135(4) which expressly specifies that, in the computation of the allocation, there may be "appropriate differences in the rate for different classes, grades or qualities thereof". ...

Wampole & Co., [1931] S.C.R. 494, [1931] 3 D.L.R. 754 at pages 496-97 (D.L.R. 754-55), the trial judge concluded, on the second issue, that the distribution of the directories by the appellant to its subscribers did amount, in the circumstances of this case, to a "use" of those goods within the meaning of subparagraph 27(1)(a)(iii). ...

Thill & Associates, which had in turn also received the necessary funds from Applied Research. ...

.: — The sole issue in this case is whether the respondent during its 1976 and 1977 taxation years manufactured or processed goods for sale or lease within the meaning of paragraph 125.1 (3)(a) of the Income Tax Act ("the Act") to entitle it to deduct from tax otherwise payable by it the manufacturing and processing tax credit provided by section 125.1 of the Act. ...

Her Majesty the Queen, [1996] 3 CTC 254 Hugessen J.A: — This is an appeal from a judgment which dismissed the appellant’s appeal of the Minister’s disallowance for the taxation years 1980 through 1983 of certain “soft” costs in relation to a Multiple Unit Residential Building (MURB) development in which the taxpayer had invested. ...

Accordingly, for all of the foregoing reasons the appeal will be dismissed with costs. 1 See, eg, Regal Heights Limited v MNR, [1960] S.C.R. 902;]1960[CTC 384; 60 DTC 1270; MNR v Foreign Power Securities Ltd,]1967[SCR 295; [1967] CTC 116; 67 DTC 5084; Warnford Court (Canada) Ltd v MNR, [1964] Ex CR 944; [1964] CTC 175; 64 DTC 5103; D C McDonald v The Queen, [1974] CTC 836; 74 DTC 6644. 2 + [1976] CTC at p 453. ...

If the employee chooses at some later date to acquire the shares, as the appellant did in the case at bar, any resulting benefit by virtue of paragraph (a) shall be deemed to have been received in the year of acquisition “... by the employee by virtue of his employment”. ... The option was granted “... in consideration of the optionee fulfilling the conditions...” set forth in the agreement. The option was “... an option to purchase 2,500 common shares of the capital stock of the Company upon the following terms and conditions...” ...

In September 1984 the appellant was contacted by Boots & Coots, a well control company based in Houston, Texas, with respect to an underground blowout in an exploratory gas well being drilled by Mobil Oil Canada Ltd (“Mobil”) off the coast of Nova Scotia. ... Interpreting the 1942 Convention The basic principles to be applied in interpreting the 1942 Convention or any bilateral tax treaty are those found in articles 31 & 32 of the Vienna Convention on the Law of Treaties. ... Canada is a member of the Organization for Economic Co-operation & Development (“OECD”) which adopted a Model Tax Convention on Income & Capital (the “OECD Convention”) in 1977. ...

See The King v Hooper, [1942] Ex CR 193; Galway v MNR, [1974] FC 600, [1974] CTC 454; 74 DTC 6355; Northrop Corp v The Queen et al, [1977] 1 FC 289; The Clarkson Company Limited & Rapid Data Systems & Equipment Limited v The Queen, No A-884-77, Judgment of the Federal Court of Appeal September 11,1978, [1979] CTC 96. ... Counsel for the Crown invokes the provisions of the Interpretation Act, RSC c 1-23 respecting the meaning of “may” and “shall”, the decision of the Privy Council in McHugh v Union Bank, [1913] AC 299 respecting the effect of such provisions on the application of the principle affirmed in Julius v Lord Bishop of Oxford, and the reliance on McHugh by the Supreme Court of Canada in Smith & Rhuland Limited v The Queen Ex Rel Brice Andrews et al, [1953] 2 S.C.R. 95. ... In Smith & Rhuland the majority of the Supreme Court of Canada held that notwithstanding the prescribed conditions for certification the word “may” made the power to certify a discretionary one. ...

Our argument is that, in some cases we are caught in the same ‘contractor’ — ‘manufacturer’ dilemma with regards to Taxation. ... As explained during the meeting, the Department holds that with reference to Section 29(2b)(a) & (b) of the Excise Tax Act, the persons who produce the goods concerned must be in competition with persons who construct or erect similar goods at site ie concrete in competition with concrete, or wood in competition with wood. ... The Supreme Court of Canada, in Goodyear Tire & Rubber Co of Canada Ltd v T Eaton Co Ltd, [1956] S.C.R. 610; has held that section 57 had no application where the question was whether a person was to be considered a manufacturer or producer for the purposes of sales tax by virtue of paragraph 2(1)(aa) of the Excise Tax Act (which at that time was paragraph 2(a)(ii) of the Act). ...