Premium Iron Ores Ltd. v. Minister of National Revenue, 66 DTC 5280, [1966] CTC 391, [1966] S.C.R. 685 -- summary under Nature of Income

A mining company ("Steep Rock") appointed the taxpayer as its exclusive agent for the sale of iron ore to be mined from the deposit under Steep Rock Lake. The taxpayer shortly after the appointment and well before the mine came into production agreed to pay 20% of the commission which otherwise would be receivable by it for its selling services to the president of one of its shareholders, and ultimately to that shareholder, in recognition of services to be rendered to the taxpayer. Ritchie J. held that because the 20% share had by an enforceable agreement become the property of that group, those amounts did not form part of the taxpayer's taxable income.