income tax

Mining taxes paid by the taxpayer to the provinces of Ontario, Quebec and Newfoundland and Labrador were income taxes the deduction of which was prohibited by s. 18(1)(a) rather than taxes in the nature of royalties the deduction of which was prohibited by s. 18(1)(m) of the Act. (The latter characterization would have resulted in the deductibility of such taxes by virtue of s. 8(1) of the Income Tax Act (BC)).

The Republic of Colombia levied, pursuant to the same tax statute under which an income tax and an excess profits tax was levied, a capital tax (referred to as a "patrimony tax") which was "based on the theory that the income tax, in order to be an equitable revenue system, requires a tax on capital to more fairly distribute the burdens amongst the nation's taxpayers and to prevent the state from being penalied if a property owner, through negligence or for some other reason, fails to realize the inherent productive potential of his property" (p. 587).