Osler, Hammond & Nanton Limited v. Minister of National Revenue, 63 DTC 1119, [1963] CTC 164, [1963] S.C.R. 432 -- summary under Shares

The taxpayer retained a portion of the common shares which were issued to it on an underwriting, and several years later sold a portion of such shares at a profit. Because the shares were received by the taxpayer as part of an underwriting transaction, the profits were taxable. The taxpayer also realized a taxable gain when rights which it received in connection with the same shares were exercised by it and the shares acquired in exercise immediately sold by it.