Lamont Management Ltd. v. R., 99 DTC 871, [1999] 3 CTC 2576 (TCC) -- summary under Subsection 55(2)

In light of the specific code provided in s. 55(5), it was found that the safe income attributable to shares redeemed in the hands of the taxpayer did not include safe income earned by a U.S. corporation in which the taxpayer was indirectly invested because that corporation was not a foreign affiliate. This was so notwithstanding that "the word 'any' is all-embracing and ... in its natural meaning it excludes limitations" (p. 877).