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During its 1972 taxation year the respondent paid taxable dividends aggregating $4,700,000 as follows: June 1, 1971 $ 750,000 December 29, 1971 $2,000,000 February 24, 1972 $1,950,000 Withholding tax at the rate of 15% was paid on those dividends. section 133 of the amended Act provides a special tax treatment for non-resident-owned investment corporations. ... The only issue is whether this amount is to be refunded, in respect of dividends paid in 1972, or whether the right to refund will arise, when taxable dividends are paid at a time subsequent to the end of its 1972 taxation year.”* [* If the plaintiff has not paid, or does not pay, any dividends after the end of its 1972 taxation year, then, on the defendant’s interpretation of the section in question, the plaintiff will never receive an allowable refund in respect of the tax levied.] ... As a result of course, the cross-appeal should be dismissed with costs. 1 133. (6) If the return of a non-resident-owned investment corporation’s income for a taxation year has been made within 4 years from the end of the year the Minister (a) may, upon mailing the notice of assessment for the year, refund, with out application therefor, its allowable refund for the year; and (b) shall make such a refund after mailing the notice of assessment if appli cation therefor has been made in writing by the corporation within 4 years from the end of the year. 2 *“ The amount referred to is its taxable income for 1972. 3 2. (1) An income tax shall be paid as hereinafter required upon the taxable income for each taxation year of every person resident in Canada at any time in the year. (2) The taxable income of a taxpayer for a taxation year is his income for the year minus the deductions permitted by Division C. ...

.: — This is an appeal from a decision of the Tax Court of Canada in which the appeal by the respondent, Fording Coal Limited (“Fording”) from a reassessment of its 1985 through 1990 tax years was allowed. ... Subsection 245(1), as it then read, stated: Artificial Transactions — In computing income for the purposes of the Act, no deduction may be made in respect of a disbursement or expense made or incurred in respect of a transaction or operation that, if allowed, would unduly or artificially reduce income. ... Strayer J.A.: — I have read the reasons of my colleague McDonald J.A. ...

VIII, Montreal, Wilson & Lafleur, 1909, page 4: I have said that the idea of representation is fundamental to a mandate. ... Smith, J. explained with respect to that province: ”... a wholesaler will not obtain a permit unless he agrees to be a collector...”. ... Charest Ltée & Rene Tessier Ltée v. New Brunswick (unreported) (February 3, 1986), New Brunswick 28/25/CA. 2 Mr. ...

Judgment A Quo The trial judge first recognized that "Prior to 1972, child care expenses were treated as non-deductible personal expenses for income tax purposes". [14] On paragraph 18(1)(a), the trial judge said that in his opinion that in his opinion that paragraph should be interpreted "in view of the social and economic realities of the times" and that he was not bound “ a cluster of cases decided in the 1950s and 1960s based on the reasoning of a decision made in 1891”. ... The federal government's Bulletin IT-487, April 26, 1982, entitled "General Limitation on Deduction of Outlays or Expenses”, states in part: (b) ”... for the purpose... ... On the question of economic rights and section 15, I adopt these observation of Hugessen, J.A. in Smith, Kline & French Laboratories Ltd. v. ...

Following communication of these terms to appellant’s counsel, and upon some sufficient indication or assurance being given that the total amount to be paid would not exceed $1,200,000 and that counsel for the Department would review the transactions involved in the Department’s computations for the purpose of assuring himself that on the information available they were properly included therein, the following document was executed by the appellant and his counsel and by Eco and on July 2, 1964 was delivered to counsel for the Department: Mr C Gordon Dilts, Barrister & Solicitor, 503 Electric Railway Chambers, WINNIPEG, Manitoba Dear Mr Dilts: Re: Mark Gerald Smerchanski and Eco Exploration Company Limited (no personal liability) We, Mark Gerald Smerchanski and Harry Walsh, hereby jointly and severally commit ourselves unconditionally to the payment in cash of the total income tax liability of Mark Gerald Smerchanski and Eco Exploration Company Limited (no personal liability) (including interest and penalties) for the years 1945 to 1959, both inclusive, as determined by the Department of National Revenue, such payment to be made upon our being advised by the said Department of the total amount of such liability. ... “M G Smerchanski” “Harry Walsh” ECO EXPLORATION COMPANY LIMITED (NO PERSONAL LIABILITY) Per: “P N Smerchanski” President “Phillip Smerchanski” Secretary On July 8, 1964, following the contemplated review by Mr Dilts, which resulted in amounts totalling $148,984.15 being eliminated from the computations of Ificome, notices of reassessments of the appellant and of Eco were delivered by hand to appellant’s counsel together with drafts of the documents here in question for execution and an accompanying letter which read as follows: July 8, 1964 Mr Harry Walsh, QC, Messrs Walsh, Micay & Co, Barristers & Solicitors, 7th Fl, Childs Bldg, Winnipeg, Manitoba Re: Mark G Smerchanski and Eco Exploration Company Limited Our File No C-51 CGD Dear Sir: Further to our telephone conversation of today’s date, we enclose Notices of Re-assessment in regard to the income tax of the above named for the years 1945 to 1959. ... Yours truly, THOMPSON, DILTS, JONES, HALL, DEWAR & RITCHIE Per: “C G Dilts” CGD*nd Encl. ...

A., [3] has the meaning of "not more extended, not going beyond what has been dealt with”, “ not going or extending beyond what exists"'. ... XI, Montréal: Wilson & Lafleur Ltd., 1961, at page 49. 9 Gagnon v. ... Faribault, Traité de droit civil du Québec, t. 7a, Montreal: Wilson & Lafleur Ltd., 1957, at page 272. 11 The appellant referred to Croteau v. ...

Gardner Mountain & D’Ambrumenil, Ltd. (1947), 29 T.C. 69 which Jackett P. cited in his now famous footnote. ... The principles enunciated in Gardner Mountain & D’Ambrumenil, Ltd. apply to it. ... Krishna & J.A. Rendall, Essays on Canadian Taxation: Basic Accounting Concepts (Toronto: Richard De Boo Limited, 1978) at page 115. 10 W.R. ...

I say this on the authority of the case of Roberts and Bagwell v Her Majesty the Queen, [1957] S.C.R. 28, which incidentally was followed by Joseph Simard & Cre, Ltée v MNR, [1964] CTC 461: 64 DTC 5289, per Dumoulin, J of ire Exchequer Court of Canada. ... It was stated in this way by Parke, B (Becke v Smith (1836), 2 M & W 191 at p 195): “It is a very useful rule, in the construction of a statute, to adhere to the ordinary meaning of the words used, and to the grammatical construction, unless that is at variance with the intention of the legislature, to be collected from the statute itself...” ... If in such a statute the word “gift” were to be limited to gratuitous transfers of property, in my view, the door would be opened wide to those who would seek to circumvent the avowed purpose of the Act by the subterfuge of disguised sales as was done by the respondent herein and by the appellant in Joseph Simard & Cie, Ltée v MNR (supra). ...

He died intestate in February, 1977 leaving him surviving his spouse Winnifred —one of the Administrators — resident at Macklin, and two sons Irvin and Gerald. ... Subsection 9(2) ordains in mandatory terms that no allowance of relief to a spouse shall be less than would go to the spouse on an intestacy and this, I think, expresses public policy in Saskatchewan as to the minimum rights of a spouse in the deceased spouse’s estate — subject, of course, to restrictions that are not applicable here. ... The Queen’s Bench order in this case ordered, inter alia: “... that the assets of the Estate of William Edward Hillis are hereby granted to Winnifred M Hillis...”. ...

. — EXHIBIT NO 17: Receipt and satisfaction signed by Pepsi Cola Canada Limited. ...