Huron Steel Fabricators (London) Ltd. v. M.N.R., 75 DTC 5006, [1974] CTC 889 (FCTD) -- summary under Subsection 15(1)

The Crown's theory was that an arrangement, whereunder (a) the majority shareholder ("Fratschko") of a private company ("Huron") acquired the shares in Huron held by a minority shareholder ("Peckham") as the result of the almost immediate default of Peckham on a loan to him by Fratschko, and (b) a contract whereunder a company ("Pelon") owned by Peckham agreed to perform services for Huron, should be regarded as a sale of shares by Fratschko to Peckham for consideration funded by the payments by Huron to Pelon under the service contract. However, the evidence established that Pelon had provided substantial services to Huron, and that the amount of the loan for which Peckham's shares were security approximated their fair market value. No shareholder benefit was conferred on Fratschko.