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:—In this appeal, wherein some difficult questions in the very debatable land of provincial powers of taxation are raised, the solution of which, we were informed by counsel, is of an urgent nature in connection with the public revenue, I do not think it is necessary or desirable to say more than to adopt the following language of Romer, L.J., in the very recent taxation case of Hennell v. ... But, so long as the terms were used only in connection with the theoretical treatment of the subject, this ‘state of things gave rise to no serious inconvenience. ...

The fire insurance on that stock is carried by the respondent and Mackenzie, White & Dunsmuir Ltd. has no responsibility in connection therewith— See ex. 4. ...

In examining the Vancouver Incorporation Act to see what type of taxation it authorizes, we should recall that municipal taxation in connexion with land involves two processes: first an assessment is made, and then a rate is imposed. ... Reference may be made first to s. 46 in connection with which it is submitted by counsel on behalf of the appellant that the words “registered owner thereof” in s. 40(1) (d) do not mean the registered owner of the improvements referred to in section 40(1) (c) but the registered owner of the "‘rateable parcel of land” referred to in section 40(1) (a). ...

(e) It is in the public interest that employees of the Department of National Revenue be able to divulge information in confidence and receive legal advice in confidence in connection with their enforcement of the Income Tax Act. ... It exists to ensure the full and frank disclosure by the client to the solicitor of all information required to enable the latter to gave informed advice to the former in connection with ongoing or pending litigation. ... That decision highlights the fact that although the two “privileges” may both be invoked in connection with the same document or communication, they must be considered and applied separately, each according to its own rules, and not as adjuncts of one another. ...

Pawlik, [1952] C.T.C. 32, that on grounds of public policy the production of income tax returns and other papers in connection therewith might be refused by the Minister of National Revenue. and that an official of the Income Tax Department, if proper objection were taken, could not be forced to give evidence with regard to income tax returns, as this would interfere with the proper and effective operation of the Income Tax Acts. ... An accused person’s guilt might be made perfectly clear by an income tax return or by papers filed in connection therewith. ...

Justice Stewart rejected any necessary connection between that amendment and the notion of trespass. ...

In this connection counsel for the appellant stated he did not propose to argue that point and conceded that the duty exercised was not of an administrative character nor ministerial. ...