Newfoundland and Labrador Corporation Ltd. et al. v. Attorney General of Newfoundland, 138 DLR (3d) 577, [1982] 2 SCR 260 -- summary under Subsection 92(2)

In finding that a tax on the net royalty income from the grant of rights to engage in mining operations was an income tax, Martland J. stated (p. 591):

"[T]he tax ... is demanded from the very person who is intended should pay it. It was not imposed in the expectation or with the intention that it should be passed on to another."