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In the first count, Charles Vernon Myers and Interpublishing Company Ltd, otherwise known as Inter Publishing Co Ltd were charged that they:. did between the 31st day of December, AD 1968, and on the 1st day of November, AD 1975, at or near the City of Calgary, unlawfully and wilfully evade payment of taxes imposed by the Income Tax Act RSC 1952, Ch 148, with respect to income received by the said Interpublishing Company Ltd, otherwise known as Inter Publishing Co Ltd, in the amount of $878,602.67 during the taxation years 1969, 1970, 1971, 1972, 1973 and 1974 from the operation of publications known as Myers Finance Review, Myers Finance & Energy, Myers Finance and Petroleum and other publications and from dealings in gold and silver bullion and coin, and from financial counselling and did thereby commit an offence contrary to Paragraph 239(1)(d) of the said Act. ... In the personal income tax returns filed by Myers, he reported taxable income as follows: 1969 $ 13,000.00 1970 13,194.00 1971 10,735.15 1972 9,664.18 1973 13,834.66 1974 68,210.95 Total $128,210.67 He reported receiving a “salary” in each of those years as part of his income but no T4 slips were ever included with his returns. ... In Snook v London & West Riding Investments Ltd, [1967] 1 All ER 518 at 528, Diplock, LJ defined “sham”: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd and the defendants were a “sham”, it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...

., summarized, [1990] 1 C.T.C. 84, 90 D.T.C. 6040 at page 86 (D.T.C. 6041), the respondents contended that the search and seizure provisions in section 231.3 were invalid because: (1) subsection 231.3(3) allows no discretion to a judge to guard against abusive searches and seizures — it requires a judge to issue a warrant if satisfied that there are reasonable grounds to believe that an offence has been committed and that evidence of that offence is likely to be found in certain premises; (2) subsection 231.3(5) allows wholesale searches and seizures, without adequate authorization, and therefore does not meet the requirements of a constitutionally valid search and seizure power, as set out in Hunter v. ... Bearing all this in mind, I conclude that subsection 231.3(3), by using the words ” shall issue”, denies the issuing judge the discretion to refuse to issue a warrant where in all the circumstances a search or seizure would be unreasonable. ... Rather, it meets the “ credibly based probability” standard required by section 8. ...

Coopers & Lybrand (Amsterdam) were appointed auditors. Unsworth explained that managing directors were analogous to officers of a Canadian corporation while supervisory directors were likened to the "Canadian-style director". ... He said at page 198 (D.T.C. 5122): “What is income from "a business other than an active business” must mean income from a business that is in an “absolute state of suspension”. ” And at page 199 (D.T.C. 5123): “Any quantum of business activity that gives rise to income in a taxation year for a private corporation in Canada is sufficient to make mandatory the characterization of such income as income from an 'active business carried on in Canada'. ... In L & F Holdings Ltd. v. M.N.R., [1975] C.T.C. 2192; 75 D.T.C. 150 (T.R.B.), Roland St-Onge, Q.C. ...

& L. Inc. (”PML) was incorporated in Delaware in 1970. At all relevant times, the shares of PML were held by Arizona. ... When the partnership purchased the hotel on December 14, 1984, the purchase price of $125,500,000 was financed as follows: First mortgage to Equitable Life $ 70,000,000 Promissory notes to vendors 33,500,000 Capital from Partnership 22, 000,000 $125,500,000 The partnership as new owner had invested less than 20 per cent of the cost. ... Marsh & McLennan Ltd., [1983] C.T.C. 231, 83 D.T.C. 5180, Ensite Ltd. v. ...

Subsequently, in 1941, the respondent, in determining the net income of the appellant for income tax purposes, ' for the year 1938, added a sum of $10,955.70, being $21.15 in respect of each of the original 518 shares of stock held by the appellant. ... With respect to section 16, it may be questioned whether the language "reduces … any class of the capital stock or shares thereof" contemplates a reduction in the par value of the shares outstanding. ... Solicitors for the appellant: Montgomery, McMichael, Common, Howard, Forsyth & Ker. ...

Payne, “ The Dichotomy between Family Law and Family Crises on Marriage Breakdown” (1989), 20 R.G.D. 109 at pages 116-17. ... Minister of Employment and Immigration, [1985] 1 S.C.R. 177,17 D.L.R. (4th) 422,14 C.R.R. 13 at pages 206-07 (D.L.R. 459-60, C.R.R. 48-49): Like “liberty”, the phrase “ security of the person" is capable of a broad meaning. ... The intentional exclusion of property from section 7, and the substitution therefor of “ security of the person" has, in our estimation, a dual effect. ...

[Translation]; (j) The amount of $175,336.71 claimed by the appellant as so-called “ incidental expenses" [Translation] does not represent expenses which it incurred during its 1982 taxation year, but rather represents various expenses which were incurred and paid by the initial promoters of the project between June 25,1982 and December 15, 1982, the whole before the appellant became owner of an interest in the said project; (k) The amount of $175,336.71 was included in the price of $1,775,698.76 mentioned in subparagraph (f) above; (1) The so-called“ incidental expenses" [Translation] claimed by the appellant in 1982 represent the following items: Incidental expenses for the entire project (including the $937,474.20 amounts appearing in Appendix A under the first, second, x 7.57% third, fourth, fifth and sixth claim headings) $72,654.25 Interest paid to the Caisse de dépôt et de placement at the rate of 19 per cent on sums advanced prior to the appel lant’s participation: 102,682.46 lant's participation: TOTAL 175,336.71 [Translation.] 3. ... So what you do in firming up a project like that is to manage to make attitudes change so that people get closer and closer to an agreement, then say, ” Yes, we’ll do it.” ... (S.N. pages 86-87) [Translation] 4.16 On August 4, 1983, an agreement was reached between Cadev, 102077 and 1849 and the group of investors having acquired an interest in the Rockland project from Cadev, that is the appellant, La Laurentienne Mutuelle d'assurance (hereinafter called "La Laurentienne") and the Montreal Police Benevolent and Pension Society (hereinafter called the “ Police Society") (Exhibit A-5). ...

Loss from farming where chief source of income not farming. (1) Where a taxpayer's chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income, for the purposes of sections 3 and 111 his loss, if any, for the year from all farming businesses carried on by him shall be deemed to be the aggregate of (a) the lesser of (i) the amount by which the aggregate of his losses for the year, determined without reference to this section and before making any deduction under section 37 or 37.1, from all farming businesses carried on by him exceeds the aggregate of his incomes for the year, so determined from all such businesses, and (ii) $2,500 plus the lesser of (A) / of the amount by which the amount determined under subparagraph (i) exceeds $2,500, and (B) $2,500 and (b) the amount, if any, by which (i) the amount that would be determined under subparagraph (a)(i) if it were read as though the words “and before making any deduction under section 37 or 37.1” were deleted, exceeds (ii) the amount determined under subparagraph (a)(i); and for the purposes of this Act the amount, if any, by which the amount determined under subparagraph (a)(i) exceeds the amount determined under subparagraph (a)(ii) is the taxpayer's “restricted farm loss” for the year. Subsection 31(1) falls under the auspices of “special cases" in Division B — Computation of Income. ... To complete the context within which the impugned provision appears in the ITA, section 11 is within Division C — Computation of Taxable Income of the legislation. ...

In James Richardson & Sons Ltd. v. Minister of National Revenue, [7] Wilson J., relying on Canadian Bank of Commerce v. ... (as he then was) in Canada (Director of Investigation &. Research, Combines Investigation Branch) v. ... I turn to the first of the “Wigmore Rules” — the documents must originate in a confidence that they will not be disclosed. ...

In England in 1867 there was a probate duty that had been levied under sucessive Acts since the Probate Duty Act, 1801, 41 Geo III, c 86; there was a legacy duty first levied under the Legacy Duty Act, 1796, 36 Geo III, c 52; and there was a succession duty, first levied under the Succession Duty Act, 1853, 16 & 17 Viet c 51. ... In Thomson v Advocate General (1845), 12 Cl & Fin 1; 8 ER 1294, the question was whether the Legacy Duty Act applied to personal property passing to a beneficiary in Scotland under the will of a testator domiciled in Demerara, where the law of Holland was in force. ... Counsel for the respondents referred to the Woodruff case and particularly to that part of the judgment appearing at 513: The pith of the matter seems to be that, the powers of the provincial Legislature being strictly limited to “direct taxation within the province” (British North America Act, 30 & 31 Vict c 3, s 92, sub-s 2), any attempt to levy a tax on property locally situate outside the province is beyond their competence. ...