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., at page 15, SAYS: ‘The owners of the majority of the voting power in a company are the persons who are in effective control of its affairs and fortunes.’ ” Now although this interpretation was given in connection with Section 39 of the Income Tax Act, I can see no reason why it should not apply as well to Section 139 (5a) of the Act in which case Lee could not have control of the appellant corporation as he held only 50% of its shares and, therefore, could not be said to have a number of shares such that he carries with it the right to a majority of the votes in the election of the board of directors or that his shareholding in the company was such that ‘‘he was more powerful than all the other shareholders in the company put together in general meeting’’ as set down by Cameron, J. in Vancouver Towing Company Limited v. ...

Convention are in agreement that it cannot be construed in a manner that prohibits the application of domestic anti-abuse rules to residents of the other contracting state, whether they are applied in the context of domestic legislation alone, or in connection with an avoidance scheme that depends upon an abuse of provisions of the Income Tax Act coupled with the U.S. ...

The 1950 deliberations of the Commission make it clear that the notion of continental shelf rights arising ipso jure was considered to be new law: The CHAIRMAN read out the text of question 9 “To what extent can there be any question in this connexion of rights already recognized under existing international law?” ...

To sum up, the connection between the prohibition and the operations carried on by farmers is too indirect and remote to bring the prohibition within the terms of s. 95, and for this reason counsel’s fourth and last argument fails. ’ ’ Now in the instant case it is suggested that the trespass on provincial rights is occasioned by the effect of the passage of paragraph (o); that taxpayers would complain to the provincial taxing authorities that they were not entitled thereunder to deduct corporation taxes, and in particular, the tax imposed by the Province of Quebec under the Act to Insure the Progress of Education, and to urge the povince not to levy any such taxes. ...

., quoted above in connection with the percentage‑of‑completion method ...

Finally, his advice was inconsistent with the factual reality that the Appellant transferred only the legal title to the properties to the corporations that acted as her exclusive agents in connection with those properties and the business ...

  [32]            Almost always, applications for judicial review of administrative actions by the Minister in connection with assessments fail, especially in this Court. ...

But they consider that they have “no real connection” with the US and that their US citizenship is “an accident of birth and of little significance”. ...

Work expended on or in connection with the property realized. There was none unless one includes the insertion of additional assets into CBL (the drag line) and the removal from CBL of six leases that CC did not want. 5. ...

It is also the first express explanation of the connection between the absence of an agency agreement and the failure to meet the disbursement quota. ...