Laxton v. The Queen, 89 DTC 5327, [1989] 2 CTC 85 (FCA) -- summary under Section 3

In a joint venture agreement it was agreed that an individual member of the joint venture ("Laxton") would be paid an annual management fee equal to $450,000 minus the product of the Bank of Montreal prime rate and the amount of interest free loans made by the joint venture to Laxton. Imputed interest on interest-free loans made to Laxton by the other members of the joint venture (who previously had borrowed from the Bank) was included in his income as "amounts" of income (which were defined in s. 248(1) as value of rights or things). "[T]he interest free loan ... was linked to and was in reality part of the overall management fee arrangement in favour of the Appellant."