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Jackett, P. in Olympia Floor & Wall Tile (Quebec) Ltd. v. M.N.R., [1970] Ex. ... Reg. 75/84, s.1 and ©. Reg. 39/85, s.1). Simpson's wages could not be considered unreasonable given this minimum and the fact that she was looking after two children. ... (page 26) At page 25 of his reasons McIntyre, J. included the following quote from Hugessen, J.A. in Smith, Kline & French Laboratories v. ...

After referring to the dissenting judgment of Beetz, J and McIntyre, J, Justice Le Dain continues at page 472 of the Cornell judgment: The conclusion that must be drawn from Beauregard, with great respect, is that the test formulated by McIntyre J. in McKay — at least that part of it which requires that the departure from the principle of equality be necessary to the attainment of the legislative purpose — has not been adopted by a majority in this Court as the test for the application of s. 1(b) of the Canadian Bill of Rights, and that, as held by the majority in Beauregard, it is too late to do so now. ... " Similarly, although spoken in a different context, Chief Justice Dickson said at p. 347 S.C.R., p. 362 D.L.R. of Big M Drug Mart Ltd., [infra] ”... the interests of true equality may well require differentiation in treatment". ... Reference should also be made to the judgment of Justice Hugessen in Smith, Kline & French Laboratories Ltd. v. ...

Langan, Snell’s Principles of Equity (London: Sweet & Maxwell, 1982) at 41. ... This Part as it relates to matters preliminary to the issue of the letters patent and supplementary letters patent are directory only; and no letters patent, or supplementary letters patent, issued under this Part shall be held void for any irreg- ularity, insufficiency or want of compliance herewith as respects such preliminary matter, … This section does not help the appellants. ... First, I am of opinion that the phrase “consideration that includes shares, ” in its plain and ordinary meaning, cannot refer to consideration that consists of a simple promise to issue shares. ...

.: — The appeal of Taran Furs (Montreal) Inc. was heard on October 17, 1995 in the City of Montreal, province of Quebec, and the issue is whether the Respondent was right in assessing the Appellant for non-resident tax and penalty with respect to the taxation years 1975, 1976 and 1977 and for non-resident tax with respect to the years 1980 and 1981 respectively. ... In assessing the Appellant for the 1975, 1976, 1977, 1980 and 1981 years, the Minister of National Revenue relied inter alia on the following assumptions of facts: (a) The Appellant carried on the business of manufacturing and selling furs in Canada; (b) In the course of this business carried on in Canada, the Appellant bought skins from non-resident suppliers, Finnish Fur Sales Ltd and Danish Fur Sales Ltd, who carried on their own business in Finland and Denmark respectively, and Hudson Bay Company in New York (USA), Nordic Fur Auctions in Stockholm (Sweden), Oslo Fur Auctions Ltd in Oslo (Norway) and Hudson Bay & Anning Ltd in London (England) who carried on their own business in the country mentioned in parenthesis; (c) Finnish Fur Sales Ltd and Danish Fur Sales Ltd had no permanent establishment in Canada during 1975, 1976, 1977, 1980 and 1981; (d) The Appellant did not carry on any business in a country other than Canada and the mere purchase of goods outside Canada does not amount to carrying on a business in a foreign country; (e) Payments of interest on late payments to the suppliers were provided in the contracts passed on by the Appellant with its non-resident suppliers; (f) During the 1975, 1976, 1977, 1980 and 1981 years, the Appellant paid or credited on late payments to its non- resident suppliers the amounts mentioned in the annex attached to this Reply, on account or in lieu of payment of, or in satisfaction of interest to its non-resident suppliers; (g) In computing these amounts so paid to its non-resident suppliers, the Appellant applied a rate of interest to its overdue payments which were outstanding after a certain length of time; (h) The interest paid by the Appellant represents interest derived from a source within Canada by the non-resident suppliers; (i) The Appellant failed to deduct or withhold tax from the amounts of interest paid to its non-resident suppliers; (j) The Appellant is liable to pay the following amounts of tax that should have been deducted or withheld: YEAR: TAX 1975: $29,913.27 1976: $20,100.72 1977: $7,120.96 1980: $ 5,844.00 1981: $2,172.00; (k) In consequence thereof, the Minister of National Revenue also assessed penalty provided by section 227(8) as follows: YEAR: TAX 1975: $2,991.32 1976: $2,010.17 1977: $712.10 At the hearing, the Appellant admits sub-paragraphs Sa) to 5c), 5e) to 5g), except for the meaning of interest and denies all the other subparagraphs. ... Smidth & Co. v. Greenwood, (1922) 8 T.C. 193 (House of Lords), cited in Cutlers Guild Ltd. above. ...

The refinery could not operate without water and, in particular, required water for four purposes: — as a coolant in the heat exchangers — as make-up water to the lube area cooling system — to produce steam in the utility plant — to fight fires 4. ...

In the present case, the structure — the system regulating access to therapeutic abortions — is manifestly unfair. ...

During the fiscal period noted above the appellant declared and paid the following dividends: Amount of Taxable Dividend Date Paid $ 750,000 June 1,1971 $2,000,000 December 29, 1971 $1,950,000 February 24, 1972 At the time these dividends were paid, the appellant withheld 15% and remitted these taxes in the amount of $705,000 to the respondent. ... This equation may be represented in this form: ART AR = x D CTI or D The application of this formula thus requires the determination of the ART and the CTI of the appellant at the time in question, which time is, for our purposes, immediately prior to the payment of the dividend on February 24, 1972. ...

Waters—Law of Trusts in Canada p 90. 2 [1895] 2 Ch 370 at 373;. 43 Digest 588, 376 approved in Re Oldfield, Old field v Oldfield, [1904] 1 Ch 549; 43 Digest 585, 339. 3 + [1897] 2 Ch 12, at 14; 43 Digest 552, 17; and see also Re Burley, Alexander v Burley, [1910] 1 Ch 215; 43 Digest 588, 377. 4 + Underhill’s Law of Trusts, supra. 5 Melroy v Lord, 4 DeG, F&J 263 at 274. ...

Cohen had an interest, be sold and the net proceeds be divided, and then this phrase, ” Dr. ... Cohen, reference is made to something that they treat as entirely different and I quote: ” Insofar as monthly maintenance is concerned Dr. ...

The amounts so conceded are as follows: PRINT ADVERTISING TOTAL 1978 $ 275,186 $1,779,751 $2,054,937 1979 1,008,368 1,708,097 2,/16,465 1980 1,136,652 3,207,602 4,344,254 TOTAL $2,420,206 $6,695,450 $9,115,656 Part XIII tax being conceded ($9,115,656 x 15%) $1,367,348 The above figures were filed on consent as exhibit 60. ... There were two separate legal entities involved and the relevant part of the business of the parent corporation in that case was described as a “mere sideline’ — refer to pages 292-93 of the above-mentioned report (CTC 142): The other and wider view of the scope of the Corporation’s business is that it embraced the supplying of geophysical services to clients but included as a sideline after May 1, 1955, the providing at approximately cost to the appellant, its wholly-owned subsidiary, of administrative, supervisory and other services, as well as equipment for the appellant’s use. ...