undertaking

The taxpayer, who orally agreed with his brother-in-law to jointly seek a franchise to supply a town with natural gas, received $10,000 in lieu of his rights in respect of the franchise which ultimately was obtained, having advised his brother-in-law that he would be required to devote most of his time to a well-servicing company, rather than to serving in a position with the gas company that was to supply the town under the franchise.

The owners and operators of a Holiday Inn in Winnipeg used television receiving equipment located on the premises to transmit programming to televisions in the guests' suites. After quoting the statement in R. v. Communicomp Data Ltd. (1975), 53 DLR (3d) 673 at 680, 60 OR (2d) 680 that "the matter becomes an 'undertaking' when there is a commercial aspect about it," Urie J found (at p.

On of the taxpayers ("Nitralloy"), which was a subsidiary of holding company ("Thos. Firth") which carried on a steel manufacturing business through other wholly-owned subsidiaries of Thos. Firth, was found not to have acquired a part of the undertaking of Thos. Firth for purposes of s. 55 of the Finance Act 1927 (UK) when Thos. Firth transferred minority shareholdings in two companies ("British Acheson" and "High Speed") to it in consideration for treasury shares.

A declaration in the 1895 federal incorporating Act of the appellant that its undertaking was a work for the general advantage of Canada (thereby bringing such undertaking under federal jurisdiction) applied to the subsequently acquired bus line enterprise of the appellant. In response to a submission that a bus line was not a physical thing and, therefore, not capable of being part of an undertaking, Rinfret J quoted with approval (at p.