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Stewart & Morrison Limited, [1970] CTC 431, [1970] DTC 6295 KERR, J. ... The so-called New York office was Stewart & Morrison Inc. a wholly owned subsidiary of the respondent. ... The letter states: In response to your request we are pleased to submit below a record of amounts received by Stewart & Morrison, Inc. from Stewart & Morrison Limited as capital contributions and loans payable. ...

& Co. Ltd. v. Minister of National Revenue, [1957] CTC 190 THURLOW, J. ... ‘ ‘ The way in which the Lord Justice Clerk applied the test is also of interest. ... " Unies you can get something worthwhile on the Drury Inlet timber, either on a lump sum or with a worthwhile deposit held so that it cannot be manipulated like the McNaughton one, we will let this timber stand hoping that prices will pick up in a reasonable period. ‘ ‘ Yours truly, • • GILLIES BROS. ...

Western Leaseholds & Western Minerals v. Minister of National Revenue, [1958] CTC 257, 58 DTC 1128 CAMERON, J. ... A.— Loans. ’ ’ Then as a result of undertakings given at the examination for discovery to produce further information, Mr. ... By a letter-agreement dated December 31, 1947 (Exhibit 19) between Minerals and Leaseholds, it was agreed that Leaseholds should retain the $250,000 option money paid by Imperial and that in respect of the Imperial agreement, Minerals would grant to Leaseholds an exclusive option to purchase from time to time up to 7 per cent of its royalty on the following basis: Per acre On the first 10,000 acres $2.63 for each 1% purchased '' 66 second 7 “ PA 10 é¢ “ “ ‘ ‘ [ar 4 third [ar {C 1.58 '' [4 H “ ** balance of acreage 1.05 “ “ “ The only clear evidence relating to these payments of $34,850.18 and $199,544.55 is found in a paragraph of Exhibit 32—an agreement between Minerals and Leaseholds dated December 30, 1950, and called ‘‘An Agreement of Settlement and Adjustments’’. ...

’ ’ Throughout the period mentioned there were three issued shares of Career Girl Store Limited (hereafter referred to as Career Girl) all of which were beneficially owned by Allied Business Supervisions Limited (hereafter referred to as Allied). ... But there was no question asking: ‘ ‘ Did beneficiaries of a trust ‘control’ or ‘have a controlling interest’ in the company?’’ ... In truth, the articles of association constitute a contract between the company and the shareholders which every shareholder is entitled to insist upon being carried out. ’ ’ That an article can restrict the right of a mere majority to bind the minority by an ordinary resolution appears from Quin & Axtens Ltd. et al. v. ...

Miron & Frères Limitée v. Minister of National Revenue, [1954] CTC 45, 54 DTC 1022 Fournier, J. ... Michel for the price of $90,000.00 and in 1949 he sold this property to Miron & Frères Limitée for the price of $600,000.00. ... The dispute between the parties is on the interpretation to be given to the words " " a corporation and one of several persons by whom it is directly or indirectly controlled shall be deemed not to deal at arm’s length’’. ...

Joseph $. Irwin v. Minister of National Revenue, [1962] CTC 572 Noel, J. ... Ch. 748, to the effect that the word ‘ from ’ ’ may mean either inclusive or exclusive accord- ing to the context and subject matter and Canadian Fina Oil Limited v. ... Justice Day stated: “... as regards time, the word ‘from’ is akin to ‘after’ and excludes the day fixed for commencement of the computation. ’ ’ In Brown v. ...

& R. Weir, Limited v. Minister of National Revenue, [1964] CTC 529 DUMOULIN, J. ... " The witness admits these particular operations were not transacted on the open market but through private contracts. ... So far, so good, but, then, whose bonds attracted that ‘ ‘ natural increment”? ...

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081 CAMERON, J. ... Secondly, a transaction which, on its true construction, is of a kind that would escape tax is not taxable on the ground that the same result could be brought about.by a transaction in another form which would attract tax. ’ ’ The question for determination, therefore, is ‘‘ What is the real character of the receipt?’’ ... C.I.R., 12 T.C. 1955, and similar cases. ’ ’ In the instant case, the appellant company retained the full ownership of its only capital asset—the Barclay Hotel. ...

William $. Walker, [1951] CTC 334 HYNDMAN, D.J.:—These two appeals were heard together. ... Mallandaine, (1887) 18 Q.B.D. 276 at 277, Lord Denman said: "The words in 5 & 6 Vict. c. 35, s. 100, Sched. ... It will be noted that Lord Denman says ‘‘ ‘vocation’ is analogous to ‘calling.’ ”’ Other decisions which might be referred to are found in Gordon’s Digest, e.g., Trautwein v. ...

Hollander & Sons Ltd. v. His Majesty the King, [1928-34] CTC 297, [1920-1940] DTC 275 MACLEAN P. ... The respondents, aS we have already observed, are not within s. 87 but, if they are a ‘producer’ or " manufacturer ‘ they are within s. 86.” ... If “transactions” means that the contract for the labour involved in dressing and dyeing the furs of customers was taxable as a sale against the dresser and dyer that would give to " " sale ” a meaning utterly foreign to the whole spirit of the Act; including even sec. 87(a), (b) and (d). ...