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A consideration of all the evidence and of the authorities and dictionary definitions to which we were referred, brings me to the conclusion that neither in technical terms nor in common speech nor in that of those who deal in such products would the skin of a mature merino sheep with the wool or hair attached to it be described as a fur. ...

The general canons of construction must be con­sidered and the meaning of words determined from a consideration of all relevant statutory or regulatory provisions. ... In his reasons for judgment, Addy J. expressed the view at p. 528:... that property in the class under consideration must actually exist before a deduction for previously acquired property of that class may be claimed. ... —The right of disposal includes, besides the right to abandon the thing and the right to destroy it, two important prerogatives: the right to alienate the thing whether gratuitously or for consideration, and the right to preserve it in the estate. ...

ON APPEAL FROM THE FEDERAL COURT OF APPEAL Maritime law—Shipping—Compulsory pilotage—Safety considerations to underlie pilotage regulations—Effect of possible bias in formulation of pilotage regulations—Validity of inclusion of ship’s flag as consideration in exemption from or waiver of compulsory pilotage—Severability of that consideration—Pilotage Act, 1971 (Can.), c. 52, ss. 12, 14, 16(1)—Pacific Pilotage Regulations, C.R.C., c. 1270, ss. 9, 10. ... The fact that these words are followed by the words “including, without restricting the generality of the foregoing”, does not, in my opinion, [Page 269] enlarge the regulation-making powers although it would command a liberal construction of the dominating consideration “in the interests of safety” specified in s. 12. ... This leaves for consideration whether LeDain J.’s view of inseverability should prevail or whether Gibson J.’s opinion, even if it be limited to s. ...

I quote subsection 83(3): 83. (3) An amount that would otherwise be included in computing the income for a taxation year of a person who has, either under an arrangement with the prospector made before the prospecting, exploration or development work or as employer of the prospector, advanced money for, or paid part or all of, the expenses of prospecting or exploring for minerals or of developing a property for minerals, shall not be included in computing his income for the year if it is the consideration for (a) an interest in a mining property acquired under the arrangement under which he made the advance or paid the expenses, or, if the prospector was his employee, acquired by him through the employee’s efforts, or (b) shares of the capital stock of a corporation received by him in consideration for property described in paragraph (a) that he has disposed of to the corporation, unless it is an amount received by him in the year as or on account of a rent, royalty or similar payment. lt is the contention of the appellant that one Joseph Conrad Frantz was a prospector within the definition of paragraph 83(1)(c) supra and that 10,000 free shares and 90,000 escrowed shares of the capital stock of Silverfields Mining Corporation Limited were acquired by the appellant’s predecessor Keevil Consultants Limited under an arrangement which the prospector made before the prospecting, exploration or development work or as an employer of the prospector and that, therefore, the income therefrom should not be computed in the income of the predecessor of the appellant, the said Keevil Consultants Limited, for the years 1963 and 1965. ... That company, in consideration for the claims, issued 700,000 shares and those shares were divided in accordance with the percentages set out in the agreement which I have quoted, so that 10,000 free shares and 90,000 escrowed shares were issued to Keevil Consultants Limited. ... It is true that in the evidence there were rather inexact and undetailed references to the hope or expected reward or bonus which, at Dr Keevil’s sole discretion, had been paid to Frantz on other occasions and which he might receive in reference to the transaction presently under consideration but no reliance whatsoever could be placed on such vague theorizing. ...

Ltd. en considération des renseignements que l’intimé avait J* 7 h.: fournis à Canadian Chemical & Cellulose Co. ... In consideration for such action on your part, we hereby waive any and all claims which we might have against the said F. ... Ltd. en considération des renseignements que l’intimé avait fournis à Canadian Chemical & Cellulose Co. ...

Mutual insurance means a contract of insurance, in which the consideration is not fixed or certain at the time the contract is made but is to be determined at the termination of the contract or at fixed periods during the term of the contract according to the experience of the insurer in respect of all similar contracts whether or not the maximum amount of such consideration is predetermined.’’ ... A premium note is defined by subsection (48) of Section 2 of the latter statute to mean:— ‘An instrument given as consideration for insurance whereby the maker undertakes to pay such sum or sums as are legally demanded by the insurer, the aggregate of such sums not to exceed an amount specified in the instrument and includes any undertaking to pay such sums regardless of the form thereof and whether or not accompanied by a deposit of money or security. ’ ’ The premium notes taken by the appellant company conform to the first part of this definition. ... Justice Hyndman, my consideration of the present matter leads me to a different conclusion. ...

I find it unnecessary and undesirable to express any opinion on the question so raised as on further consideration it appears that it does not arise on the pleadings. ... Section 3(3)(a) of the Estate Tax Act enacts: 3. (3) For the purposes of paragraph (c) of subsection (1), (a) the artificial creation by a person or with his consent during his lifetime of a debt or other right enforceable against him personally or against property of which he was or might be competent to dispose, or to charge or burden for his own benefit, shall be deemed to be a disposition by that person operating as an immediate gift inter vivos made by him at the time of the creation of the debt or right, and, in relation to any such disposition, the expression “property” in this Act includes the benefit conferred by the creation of such debt or right; Of course, s. (3)(1)(c) applies only to dispositions made within three years prior to the death and the agreement of March 15, 1961, is not within that period, but this does not mean that s. 3(3)(a) is to be left out of consideration entirely. ... They are therefore left out of consideration. I concur in the disposition of the case as proposed by the Chief Justice. ...

In seeking to appeal from the reassessments in the face of the waiver agreements which were witnessed by their advising counsel, the taxpayers contended that the waiver of rights of appeal, otherwise open to them under the Income Tax Act, was not binding upon them because (1) the waivers were based upon an illegal consideration, namely, the “For concurring reasons by Pigeon, J (concurred in by Beetz, J) see p 496. stifling of a prosecution for fraudulent tax evasion; (2) they were procured by undue influence or coercion under an implicit threat of such prosecution; and (3) they were contrary to public policy and contrary to statutory policy reflected in income tax legislation respecting a taxpayer’s right to challenge unjust tax assessments or reassessments through the courts. ... Thurlow, JA (as he then was) for the majority noted that the issue of illegality of consideration had been abandoned at trial, and he said also that the trial judge’s finding against undue influence, duress or coercion was not challenged on appeal, leaving for argument only the question whether the waiver agreements were contrary to public policy and to the provisions of the Income Tax Act. ... There are no such considerations in the present case. Although I do not think that undue influence exists in this case as a separate basis for impeaching the waiver agreements, it is my view that, assuming that they would be voidable on that ground, Smer- chanski’s conduct would disentitle him to any relief. ...

The executor of Henry now appeals to this Court against this double levy of duty and the questions for consideration in this appeal are, first, the nature of the devolution of property when Section 36 of The Wills Act comes into operation, and second, whether by the terms of the Succession Duty Act a double duty is possible even if the property disposed of by Henrietta in favour of her deceased brother does first go into the brother’s estate. ... I turn now to the consideration of the terms of the Dominion Succession Duty Act. ... Perry, [1934] A.C. 477, against a consideration of statutory origins and exolption as an aid to interpretation is particularly appropriate here where the two Acts differ so fundamentally. ...

It is to be noted that the learned Chief Justice used the firmly established principle that the taxing statute must be interpreted by the consideration of the words thereof in the ordinary, proper, and natural sense, and that doing so he found himself able to distinguish between the two words ‘‘produced’’ and “manufactured”. ... Vandeweghe Limited, supra, Duff, C.J., upon commenting that the words ‘‘produce’’ and “manufacture” were not words of any very precise meaning, sought an aid to construction in consideration of the exemptions from the impositions which were listed in subsection (4) of Section 86 of the then statute. ... I view these considerations of both the exemptions in Schedule III to the Excise Tax Act and the items in the Customs Act as being confirmatory of my view that the legislators intended that the words ‘‘manufactured’’ or ‘‘ produced’’ should encompass goods such as the polished marble slabs in question in this appeal. ...