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The contract here was "entered into" in 1918 and it is that contract which must be considered, not the situation existing after January 1, 1939 [Page 169] (when, so appellant contended, all insurance features had dropped and, whatever the contract was before, it was then an annuity contract with the characteristics of Government contracts): the payments arising in 1939 flowed from the obligations created in 1918; what the legislation contemplated was an annuity contract as of the time it was made, not as of any moment thereafter which might mark the beginning of some stage of performance under it. ... Subsequent to that decision, paragraph (b) of section 3 of the Act as considered in the Shaw case was repealed and there was substituted therefor the following: (b) annuities or other annual payments received under the provisions of any contract, except as in this Act otherwise provided. ...

Parker considered that if such a trusteed pension plan could obtain a really high yield on its investments, the privilege of participating in it would help him attract and retain desirable executive personnel. ... These were all considered and rejected in the Court below. Those grounds were all raised again in this Court, but I do not find it necessary or desirable to express an opinion on any other than the following point which is, in my view, decisive of the case. ...

The appellant, on its part, also considered itself a member otherwise it would not have been able to sell its interest to Mr. ... I have considered with care all the evidence of these witnesses bearing on this point and have reached the conclusion that it should be found as a fact that by March 31, 1957, the fair market value of the appellant's interest in the Jerd Syndicate did not exceed $1. ...

The expression class or kind as found in tariff items 427 and 427a must be considered with a reasonable degree of narrowness in that only similar machines must be considered in a determination that a particular machine is of the same class or kind of machine. 13. ...

The appellant repeats the same argument before us, namely, that classification according to recognized trade sizes is incorrect and that the Board and the Exchequer Court should have considered whether the imported shovel entered into competition with domestic production; that they should have found that the two and a half cubic yard size was competitive in some respects with the two cubic yard size, and that if it was competitive with something made in Canada, it could not be described as being of a class or kind not made in Canada. ... Before the Tariff Board it was remarked that the purpose of these items in juxtaposition was doubtful, to which I can only reply that if there is any other purpose apart from revenue than protection, it has not been mentioned nor am I able to imagine it; any benefit in a lower duty to the Canadian consumer disappears when a similar Canadian machine is available; and a dumping duty would be absurd if only prices to the consumer were being considered. ...

Superintendent of Income Tax, [1942] S.C.R. 435, considered; Provincial Treasurer of Alberta v. ... Issue was taken by counsel for the appellants with Seaton J.A.’s assertion that “it is impossible to say that there is in this Act one charging section”, but I take that to mean in the light of other parts of his reasons, that the charging provisions of s. 3 had to be considered in association with other provisions of the Act which defined various terms used in s. 3. ...

It must also be considered that the power of issuing a definition is to be exercised in good faith and it would be usurpation of power for the Minister to suppress the exemption by issuing no definition. ... The specific exemption allowed to the New Brunswick Electric Power Commission cannot create an inference to restrict the scope of other exemptions seeing that it reads: (ff) goods purchased by the New Brunswick Electric Power Commission for direct use in producing electricity; I might add that transformers are considered exempt from sales tax under the federal exemption previously mentioned. ...

He considered that the immovable encumbered by the trust deed is, within the meaning of s. 47 of the Act, "property of the bankrupt" which vests in the trustee in bankruptcy. ... As all the proceedings and the court sale took place outside the bankruptcy, the Court of Appeal considered that only the rules of provincial law are relevant. ...

Respondent, the Minister of National Revenue, considered the drivers of these vehicles to be subject to the Unemployment Insurance Act and assessed appellant for a total of $49,476.92 in premiums for these drivers. ... Even if one accepts, as I am prepared to do, appellant’s contention to the effect that the jurisdiction of Parliament under s. 91(2A) of the Constitution, considered apart from other powers of Parliament, must be qualified by an insurance aspect, it does not at all follow, in my view, that self-employed persons can never incur any insurable risk of unemployment or that in enacting s. 26(1)(d) of the Act of 1955 and s. 4(1)(c) of the Act of 1971, Parliament has deviated from the insurance approach. ...

From these two provisions it can be seen that Parliament considered how bankers' acceptances should be treated for purposes of Part I.3 of the Income Tax Act and determined that, for the years under appeal in this case, the indebtedness represented by a banker's acceptance must be included in the taxable capital of the drawer or issuer. ... Thus, for purposes of the legislation under consideration in Air Canada, the indebtedness represented by the bank paper was considered to be more like loans or advances to the bank than cash on deposit with the bank. ...