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However, according to him, as the plaintiffs, at the time of the construction, were the sole shareholders of Terminal Centre Corporation, this company should be considered as having built for the benefit of the plaintiffs, more or less as their agent. ...

The meaning of the word “property” as used in said section was considered by Mr Justice Rand of the Supreme Court of Canada in the case of Canada Safeway Limited v MNR, [1957] CTC 335 at 345-6; 57 DTC 1239 at 1244-5. ...

The parties to the agreement of January 12, 1966 (Exhibit R-3) being persons, were resident in the city of Montreal, in the province of Quebec, or being companies, were controlled by residents of the province of Quebec, and the agreement was drawn by Quebec lawyers; therefore, the contract would be in the law of Quebec, and the following cases, although decided by common law, may be considered in determining what is income or capital under the Income Tax Act, in particular the meaning of subparagraph 6(1)(a) (v) and paragraph 139(1)(aj) of the Act. ...

The respondent raises a right of incontestability and bases his contentions on the following points: (a) The insurance policies taken out by Honoré were assigned free of charge and the assignment was not registered in accordance with articles 804 and 806 of the Civil Code; (b) Notice of the assignment, even if it is considered an assignment for valuable consideration, was never served on the insurers and was never registered at the head office of the insurance companies before the death of Honoré Hawey. ...

The Department has looked at the situation and has considered certain factors. ...

During the taxation years in question there was no prohibition that restricted the right of the pension plan trustee to invest funds under their control in any investment that they considered advisable. ...

Cattanach, J in CBA Engineering Ltd v MNR, [1971] CTC 504; 71 DTC 5282, considered the meaning and purpose of section 13. ...

A good deal of evidence was given as to the various schemes proposed and considered as to how the appellant could develop these gas storage areas and still comply with the requirement they must be owned and operated by an Ontario company. ...

But their statements as to the acquisition of the land must be considered objectively along with all other relevant evidence. ...

He said that he considered there were sufficient cherry trees in the orchard to more than cover the costs of operation, cherries being a high-income-producing type of fruit. ...