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., in connection with the law as to the registration of titles in the province of British Columbia, and came to the conclusion that, though the purchaser of real estate might before conveyance have an equitable interest capable of registration, such interest was in every case commensurate only with what would be decreed to him by a Court of Equity in specifically performing the contract, and could only be defined by reference to the relief which the Court would give by way of specific performance. [21] This was echoed by the Ontario Court of Appeal in The Montreal Trust Company v. ...

Section 26 of the Revenue Administration Act reads: 26(1) Every collector who collects a tax shall be deemed to hold the tax in trust for Her Majesty in right of the Province and for the payment over of the tax in the manner and at the time provided under this Act, and, notwithstanding subsection 72(2) of the Workers' Compensation Act, the amount shall, until paid, form a special lien upon his entire estate, on the entire assets of his estate in the hands of any trustee, and upon all his property used in or in connection with or produced in or by the business of the collector, in priority to every claim, privilege, lien or encumbrance, whenever created, subject only to taxes levied under the Real Property Tax Act. 26(2) The lien in subsection (1) (a) attaches upon the date the tax is collected by the collector and does not require registration or filing of any document or the giving of notice to any person to create or preserve it, (b) attaches to all property subsequently coming within the class of property described in subsection (1) until the amount due and payable including interest and penalties, if any, has been fully paid, and (c) subject to subsection (3), follows any property to which it attaches into whosever hands the property comes. 26(3) Where a lien has attached to property that is the stock in trade of the collector and that property is disposed of in the ordinary course of business of the collector, the lien shall be extinguished upon the bona fide sale of that property made in the ordinary course of business. 26(4) Where any property referred to in subsection (3) is sold or otherwise disposed of the amount due and payable including interest and penalties, if any, is a first charge on the proceeds of the sale or disposition of that property. 26(5) Any mortgagee, judgment creditor or other person having any claim, lien, privilege or other encumbrance upon or against any property to which is attached a lien under subsection (1) (a) may pay the amount of such lien, (b) may add such amount to his mortgage, judgment or other security, and (c) has the same rights and remedies for such amount as are contained in his security. [12] I have some difficulty in seeing just how the obligations of the company became the obligations of the appellant so as to entitle the Minister of Finance and the WHSCC to place liens on the appellant's property. ...

The repeated errors and the use of different names to designate a single entity are puzzling, to say the least. [45] Although the appellant issued T4A slips and completed T4A Summary forms on which it identified itself, under different names, as the employer of the workers concerned, the documents adduced as evidence prove on a balance of probabilities that the workers' connection was with 2755963 Canada Inc. ...

The Appellant explained that the amount of $2,835.00 was for expenses in connection with the sale, or rather the exchange of his condominium for another one located on Lake Memphremagog, which leads to the question whether these expenses were properly claimed as current expenses. ...

While he could not recall certain events respecting what he had done in connection with the valuation, he was so impressed with the frailties of the car that, for his company's protection, he included the following sentence in his appraisal opinion letter, namely: This does not constitute an offer to purchase. [12] The Respondent did not produce any valuation evidence. ...

By reviewing the seven pages, one can see that the account covers the period from May 4, 1995 to February 19, 1996 when apparently a judgment was obtained in connection with the proceeding against the former husband. [6] The Appellant's claim is based on the fact that she was enforcing the collection of monies owing by her former husband with respect to the maintenance of their two children. ...

Paragraph 18(1)(a) sets out a general prohibition denying a deduction unless the amount is paid or incurred for the purpose of gaining or producing income while paragraph 18(1)(h) limits the deductibility of personal and living expenses which are defined in subsection 248(1) as follows: “personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, [Emphasis added] (b)... [10] Even if one were to assume that the Orders made by the Ontario Court in the Appellant's matrimonial proceedings gave him the right to recover portions of certain support payments made to his former spouse and that this right constituted "property" for the purposes of the Act, the amounts, if and when recovered, cannot logically be considered to be income, i.e. profit from that "property". ...

There was a telephone connection between him and Maryan in circumstances where there were two witnesses in attendance upon the Appellant here in Canada and there were two other witnesses in attendance upon Maryan in Kenya. [6] Before the Appellant testified, a witness was produced, Mr. ...

I have trouble seeing a connection between that fact and the existence of malicious intent to deceive the Minister. ...

I discuss this point below in somewhat greater length in connection with the Lee case (infra). ...