Costigane v. The Queen, 2003 DTC 254, 2003 TCC 67 -- summary under Section 67

By services, 28 November, 2015

A family trust was established which employed, on a part-time basis, three individuals previously employed full-time in the taxpayer's dental practice, and charged an administration fee to the taxpayer equal to four times the cost to it of employing the three individuals.

Miller T.C.J. found that the 15% mark-up allowed by the Minister was reasonable, whereas the deduction of the full amounts by the taxpayer was not.

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