Minister of National Revenue v. Dworkin Furs (Pembroke) Ltd. et al., 67 DTC 5035, [1967] CTC 50, [1967] SCR 223 -- summary under Paragraph 256(1)(a)

Dworkin Furs Ltd. owned 48% of the issued shares of Dworkin Furs (Pembroke) Limited in its own name and 2% in the names of Roy Saipe and Helen Saipe as its nominees, with the other 50% being owned by Sadie Harris. In light of the test of de jure control enunciated in the Buckerfield's case (64 DTC 5301 at 5303), in these circumstances Dworkin Furs (Pembroke) Limited was not controlled by Dworkin Furs Ltd. for purposes of s. 39(4)(a) of the pre-1972 Act.