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In this connection I would quote from Royal Trust Co. v. Kennedy [1930] S.C.R. 602, where, in delivering the judgment of the Court, Neweombe, J. said (p. 611): "It must be realized that the vendor, as the owner, is primarily liable for the taxes, and that the covenant, whereby the purchaser becomes bound to pay, while it serves to engage the purchaser’s indemnity for the vendor, does not create any direct obligation as between the purchaser and the municipal authorities.” ...

It is upon this section of the Act, particularly s. 87(c), that the plaintiff must rely for the recovery of the tax, in connection with tires retreaded for the customer. ...

Receipt was acknowledged in a letter dated October 19, 1932 (Ex. 21), an excerpt from which reads: " A transfer of the area from Miami Corporation to Abernethy-Lougheed Logging Company Ltd. has been filed but in filing this transfer the Department accepts no responsibility as to title or otherwise/ ‘ The agreement between the province and the Dominion bound the province to fulfil any obligations in connection with the railway belt lands that were binding on the Dominion. ...

I am bound to assume upon the evidence before me that the Minister never made such a direction, or even approved of the Appraisers’ Bulletin issued in this connection, to customs and excise officers. ...

It is true that certain difficulties are likely to arise in connection with the identity of the money in Alberta as being the money paid in respect of the dividends in question but when, as here, that identity is admitted, I think it is subject to taxation. ...

In 1933 the addition of what is now s. 8(1) (d) provided in effect for the assessment of every person carrying on the business of selling or disributing goods to a chain of more than five retail stores or shops directly or indirectly owned, controlled or operated by him ‘‘for a sum equal to 75% of the assessed value of the land occupied or used by him in such business for a distribution premises, storage or warehouse for such goods, wares and merchandise, or for an office used in connection with the said business. ’ There was a higher rate of assessment for business tax imposed upon that part of the land and buildings used in the Loblaw Co’s business for a special purpose. ...

Then s. 66 provides as follows:— Subject to the provisions of this Act, the Exchequer Court shall have jurisdiction to hear and determine all questions that may arise in connection with any assessment made under this Act and in delivering judgment may make any order as to payment of any tax, interest or penalty or as to costs as to the said Court may seem just and proper. ...

If it were its obligation to pay money to the Firestone Company could arise only because of such sales or at any rate in connection with such sales. ...

There is also a provision that the Crown will indemnify the companies against any action or claim relating to the infringement of any patent in connection with the aeroplanes, engines or other equipment supplied to the companies. ...

There is also a degree of connection in directorate personnel but it is quite impossible to say, for instance, that the bauxite company does not function in its own right as a corporate body exercising discretion, directing its local affairs and generally serving the purpose for which its incorporation was intended. ...