In commenting on the relevance of cases decided under the Finance Act, 1894 (U.K.) to the interpretation of the Dominion Succession Duty Act (Canada), Judson J. stated (p. 1168):
"The two Acts differ so widely in structure and incidence of taxation that cases decided under one Act are of little assistance to the interpretation of the other and it is of no help that sections of one Act may have been copied from the other. The Dominion Succession Duty Act must be construed independently and the caution expressed in Attorney-General for Ontario v. Perry, [1934] A.C. 477, [1934] 4 DLR 65, [1934] 3 W.W.R. 35, against a consideration of statutory origins and evolutions as an aid to interpretation is particularly appropriate here where the two Acts differ so fundamentally."