in respect of

$300 received by an employee of a life insurance company pursuant to its policy of paying such amounts to all of its employees who passed the difficult Life Office Management Association courses would, in the absence of s. 56(1)(n), have been taxable as falling within the broad words of s. 6(1)(a). Although to be taxable under s. 6(1)(a) a payment must be received in one's capacity as employee, there is no requirement that "the payment must partake of the character of remuneration for services".

A trustee in bankruptcy of a taxpayer was permitted to introduce testimony of two Revenue Canada officials in proceedings instituted in the New Brunswick Court of Queen's Bench for a declaration that certain assets registered in the name of the taxpayer's wife were held in trust for the taxpayer's estate. After noting (at p. 5447) that the phrase "relating to" in s. 241(3) had the same wide scope as "in respect of," Iacobucci, J.

Section 32 of the Crown Liability and Proceedings Act applied to prohibit the taking of collection action against the taxpayer six years after a cause of action against him arose, namely, the expiry of the 90-day period after the mailing of a notice of assessment to him. There was no authority to support the proposition that the Income Tax Act was complete code that could not be informed by laws of general application such as s. 32, the ordinary meaning of the phrase "proceedings ...

Wages of an Indian residing on an Indian reserve that were paid to him by an employer also resident on the reserve fell within the exemption from taxation in respect of personal property situate on a reserve. The reserve was the situs of the wages paid to him, the wages were his personal property and income taxes would in reality be a tax on that property.

S.6A of the Succession Duty Act (BC), which provided that "where property of a deceased was situated outside the Province at the time of the death of the deceased, and the beneficiary of any of the property of the deceased was a resident at the time of the death of the deceased, duty under this Act shall be paid by the beneficiary in respect of that property of which he is the beneficiary", was intra vires the Province in that it imposed a tax on persons within the Province (i.e., resident beneficiaries), rather than being a tax on property or on the transmission of proper