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All the money Premura received during its existence was, except for some incidental returns on invested funds less losses suffered on investment, three payments — one of $14,624.25 received by Premura in May 1963, and two in 1964 totalling approximately $32,539. ... Perhaps the following quotation from the “Switzerland Law Digest” by Drs Pestalozzi and Gmuer of the Zurich Bar in the Martindale-Hubbell Law Directory (1966 ed, R R Donnelley & Sons Company, Chicago, Illinois) page 3278, concerning the incorporation of a Swiss joint stock company may explain why, according to the appellant, Dr Frick had asked for the moneys sent over in 1963: The following data have to be recorded in the Commercial Register: date under which the articles have been passed, corporate name and seat of registered office of the corporation, purpose, proposed length of existence, amount of capital, amount paid up, par value of shares, type of shares issued, property received in payment of shares,... ...

The tax payable was computed as follows: Market value of the property at 16/6/56 $55,000.00 Cash consideration paid $2,000.00 Legal cost, purchase of rights 2,000.00 4,000.00 Gift 51,000.00 Exemption (section 112(2)) 4,000.00 Amount subject to tax $47,000.00 Tax at 15% $ 7,050.00 Penalty for late filing 5% 352.50 $ 7,402.50 To arrive at the above result respondent converted a sale into a gift, on the pretext that in 1956 the immovable sold had a higher market value than the consideration shown in the deed of sale. ...

Apparently the drinking problem continued and eventually — in the early summer of 1967, it would appear from the evidence — Hatton was discharged by Mr Gladstone on behalf of the company. ...

</p>] 16 It seems clear to me that subparagraph (x) is to be referred to if subparagraphs (i) to (ix) are inapplicable, as they obviously are in this case. 17 My interpretation of the meaning of subparagraph (x) is that, if less than 10% of the gross revenue of a taxpayer is “from the selling or leasing of goods manufactured or processed in Canada by it ” its profits do not fall within the definition of “Canadian manufacturing and processing profits” and therefore, by analogy, in order for its profits to come within that definition, more than 10% of its gross revenue must come from goods “manufactured or processed in Canada by it ”. ...

In 1973 the appellant was a representative for Richard & Frères Inc. of Ste-Foy, Quebec. ... In his 1973 income tax return the appellant claimed a gross income of $7,386.96: $5,047.50 in commission from Richard & Frères Inc, and the balance from Beau Rivage Construction Ltée. ...

.”, (d) Clause 8 of the said special clauses contained a prepayment privilege whereby the appellant could repay the balance of the loan upon receipt by the lender of an indemnity. of 6 months interest on the balance; (e) In the account dated November 8, 1972, submitted by Credit Foncier Franco-Canadien to the appellant the said amount of $40,000 is broken- down as follows: Valuation fee $ 2,500 Fees for examination of title deeds $ 2,500 Indemnity $35,000 (h) From the proceeds of the said loan, the appellant invested $3,000,000 in short-term certificates bearing interest at a rate lower than the 9 /2% rate paid for the mortgage loan. ...

In any event the total annual office expenses of the Venture shall not exceed 8V2 % of the total value of its sales invoices less any amount charged as sales taxes: The evidence indicates that these two clauses of the agreement were carried out which, in my view, greatly weakens the appellant’s contention that it manufactured or processed Dorothy Dean products. ... Richler RICHLER, LERNER, WOLMAN & CO, Chartered Accountants MMR:rk These documents taken singly or together indicate to me that the actual manufacturing of Dorothy Dean products was contracted out by the appellant company and manufactured or processed by Plastic Fabrics. ...

The key provisions of the agreement are as follows: (a) Overall agreement dated March 26, 1973 between the appellant and Nord Transport, Strandheim & Sensaker, hereinafter referred to as NTSS regarding the MV Hansa Bay: (i) Clause 1(b) provided that the vessel at that time was owned by Schiff- fahrtsgesellschaft Sensaker MS Hansa Bay, a German Company; (ii) Clause 1(c) provided that NTSS had charter rights to the vessel and also the right to subcharter her; (iii) Clause 1(d) stated that NTSS will become the sole owner of the vessel in January or February of 1975; (iv) Clause 2(i) stated that the parties were entertaining bareboat charter, hire-purchase, and management agreements contemporaneously with the overall agreement; (v) Clause 2(ii) also noted that the bareboad charter shall govern the terms of the appellant’s possession of the vessel until NTSS becomes the sole owner; thereafter terms of the hire-purchase agreement shall govern; bareboat charter payments are to be credited to hire-purchase agreement; (vi) Clause 5 stated that the appellant can obtain clear title and full ownership of the vessel after March 1, 1975 upon full payment of the balance of the purchase price; (vii) Clause 6 provided that if NTSS does not become the sole owner of the vessel by April 30, 1975, the terms of the bareboat charter shall govern, except that NTSS shall be required to give the appellant a sister ship for purchase at the same price with amounts paid on the bareboat charter credited to the purchase price; (viii) Clause 12 permitted assignment of appellant’s interest in bareboat charter and hire-purchase agreement as security for loan or guarantee; (ix) Clause 14 noted that if the vessel becomes a complete loss at any time after its delivery, NTSS is to recover the insurance proceeds in full, and from such proceeds: mortgages and other charges on the vessel will be paid: a designated amount will be retained by NTSS; and then a specified amount will be paid to the appellant. ... As can readily be seen, there were a number of interlocking complex agreements entered into between the appellant and Nord-Transport Strand- heim & Sensaker, a company organized and existing under the laws of Norway. ...

Furness, Withy & Co Ltd v MNR, [1966] CTC 482; 66 DTC 5358; 6. Coleman E Hall v MNR, [1970] CTC 510; 70 DTC 6333; 7. ... M Granatstein & Sons Limited v MNR, 13 Tax ABC 194; 55 DTC 396; 10. ... M Granatstein & Son Limited vs Minister of National Revenue, 13 Tax ABC, 194 at p 198 and p 199; 11. ...

., at which time he would proceed to his office at the Clinic for appointments extending possibly until 5:30 — provided he was not recalled to the hospital during the afternoon, a circumstance which would delay the completion of his normal working day. ... I will see him tomorrow morning — I’ll see him twice again tomorrow — and this will not show as a hospital visit. ... If perchance there was a minimal personal use to be imputed to his “professional” car — which Dr White did not admit but firmly denied — then that minimal use, he argued, had been more than offset by the use of his personal or family car for business purposes when his “professional” car was inoperative. ...