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Lagueux & Frères Inc., [1974] C.T.C. 687, 74 D.T.C. 6569 (F.C.T.D.); The Queen v. ... In Lagueux & Frères the contract in issue gave the "lessee" an option to purchase the equipment at a nominal price at the end of the lease. ...

Carnaby, Narrower, Barham & Pykett, [1970] 1 All E.R. 502; [1970] 1 W.L.R. 276 as a case that parallels the one before me. ... Plaintiff contends that the defendant, in 1985, amended the Income Tax Act by adding paragraph 12(1)(x) which states: 12.(1)(x) payments as inducement or as reimbursement etc. — any amount (other than a prescribed amount) received by the taxpayer in the year, in the course of earning income from a business or property, from (i) a person who pays the amount (in this paragraph referred to as “the payor”) in the course of earning income from a business or property or in order to achieve a benefit or advantage for himself or for persons with whom he does not deal at arm's length, or (ii) a government, municipality or other public authority where the amount can reasonably be considered to have been received (iii) as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv) as a reimbursement, contribution, allowance or as assistance whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of the cost of property or in respect of an expense to the extent that the amount (v) was not otherwise included in computing the taxpayer’s income for the year or a preceding taxation year. ...

The following two paragraphs (at page 3) under the heading “ Roll Recovering Expenses" bear reproduction. ... There is no doubt that the covering of the steel rolls is replaced but the recovering has to be replaced because it is worn, not because it is "decayed" or “ damaged”. ...

That paragraph is virtually identical to clause (b) [of the definition of “value” in] subsection 2(1) of the BC Succession Duty Act but for the additional words at the end of subparagraph 58(1)(s)(ii) “... without regard to any increase or decrease in such value after that date for any reason”. ... However, I am compelled to adopt the words of Cartwright, CJC that “... it would require clear and unambiguous words to bring about such a result” Beament Estate v MNR (supra) at 687 [198, 6133]. ...

Fleming & Co. (Machinery), Ltd. (1951), 33 T.C. 57 (Ct. of Sess.). 3 See e.g., The Glenboig Union Five Clay Co., Ltd. v. C.I.R. (1922), 12 T.C. 427 (H. of L.) at 39-40; Barr, Crombie & Co., Ltd. v. ...

The plaintiff was federally incorporated in Canada in 1971 as a wholly- owned subsidiary of Angostura Bitters (Dr J G B Siegert & Sons) Limited, a Trinidad corporation which fell heir to the secret formula of the famed aromatic elixir “Angostura Bitters’’ discovered in 1824 by Dr Siegert, while Surgeon-General in the revolutionary army of the great Venezuelan liberator, Simon Bolivar. ... Since 1968, Angostura Bitters (Dr J G B Siegert & Sons) Limited had been thinking about taking over the distribution and marketing of Angostura Bitters in the United States and had made its intentions known to All World and its parent corporation, Iroquois Brands, Ltd. ...

.: — These appeals were heard together on common evidence. The years under appeal for Mike Adams are 1984, 1985, 1986, 1987 and 1988. ... Rayner & Keeler Ltd. (No.2), [1967] 1 A.C. 853 at page 935; Angle v. ...

Rutland Moving & Storage Ltd., [1991] l C.T.C. 517 at 521 (B.C.C.A.) ... In an article entitled, “The Taxation of Corporate Reorganizations”, which appeared in Volume 4 of the 1997 edition of the Canadian Tax Journal (Tab 13), author Mark Brender of the law firm of Goodman, Phillips & Vineberg in Montreal, Quebec, specifically addressed the meaning of the word “any” as it appears in subsection 55(2) of the Act as follows at page 807 of the article:...there is no statutory basis for limiting the consolidation of safe income to controlled or significantly controlled corporations and that the safe income of any corporation should be included in the computation of safe income of the parent, regardless of how small the interest of the parent may be. 26. ...

In support counsel primarily relied on Ben Matthews & Associates Ltd. v. ... M.N.R., [1978] C.T.C. 2082, 78 D.T.C. 1087 (T.R.B.); Atkins & Durbrow Ltd. v. ...

.: — The Minister of National Revenue reassessed the Appellant by Notices of Reassessment dated June 14, 1993 for its 1989, 1990 and 1991 taxation years disallowing dividend refunds to it as follows: 1989- $109,254 1990- $126,386 1991- $113,570 TOTAL- $349,210 The Appellant claimed the dividend refund in respect of the following dividends paid on its Class “B” shares to Tingley Leasing Venture Capital Inc. ... Maritime Telephraph & Telephone Co. v. Canada) [1992] 1 C.T.C. 264, 92 D.T.C. 6191 (F.C.A.), MacGuigan, J.A. at page 267 (D.T.C. 6194), without reasons for the reference, said, This interpretation is, I believe, supported by the only extrinsic evidence available. ...