Les Entreprises Réjean Goyette inc. v. The Queen, 2009 DTC 1880, 2009 TCC 351 -- summary under Income-Producing Purpose

Management fees paid by the taxpayer to an affiliated company which had non-capital losses were non-deductible by it given that the only evidence of services provided in consideration for the management fees was of services provided by the indirect sole shareholder of the two corporations, who had already been fully paid for his services by the taxpayer. Furthermore, the fees were paid by the taxpayer without it being legally bound to do so.