Covert et al. v. Minister of Finance of Nova Scotia, [1980] CTC 437, [1980] 2 SCR 774 -- summary under Drafting Style

Succession duty imposed by Nova Scotia on Nova Scotia residents of an Alberta corporation whose wholly-owned subsidiary received the residue of the estate of their Nova Scotia-domiciled grandfather, was not a tax on property outside the province but, rather, a tax upon persons within the province measured by the benefits which they derived as a result of the bequest made to the Alberta corporation. Accordingly, the provisions imposing such tax were intra vires the Legislature of Nova Scotia.