The Queen v. Fingold, 97 DTC 5449 (FCA) -- summary under Subsection 15(1)

A holding and management company owned by the taxpayer and his brother conferred a taxable benefit on the taxpayer when it purchased a Florida condominium (in the building where the taxpayer's mother had an apartment) at a cost of Cdn. $1.8 million, renovated and upgraded the condominium at a further cost of Cdn. $2.2 million and then provided the condominium free of charge (with the exception of the payment of some operating expenses) to the taxpayer and his family, who used it for winter vacations and for business entertaining on numerous occasions. There was no error in the assumption of the Minister that the "equity rate of return" method should be used to compute the shareholder benefit, i.e., calculating what the company could have earned on the money it had used in acquiring and renovating the condominium.