In 1999, an individual, Mr. A, acquired shares of a small business corporation (the "Corporation") through his RRSP, and subsequently, personally made interest-free loans to the Corporation. In December 2005, the RRSP sold the shares for $1, and the corporation was insolvent. The Directorate stated:
Mr. A appears to have advanced the funds to the Corporation for the purpose of providing capital to the Corporation and he probably expected to realize income from the Corporation through his RRSP which is property.
Given … Byram, we do not believe that Mr. A's loss should be deemed to be nil solely because the Corporation's shares were acquired by the RRSP and not personally by Mr. A.