Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA) -- summary under Subsection 15(1)

The appellant majority shareholder of a company, who agreed to purchase the shares held in the company by a minority shareholder in consideration of having the company first pay a dividend to the minority shareholder of $350,050, was found to have received a benefit of $350,050 in that the payment of the dividend satisfied his obligation to pay the price of the shares. "It is undeniable that a payment by a corporation, whatever its form, which has the effect of extinguishing a debt or obligation of a shareholder must be considered to be a benefit conferred on him ... The value of what he acquired in consideration of the debt or obligation is really irrelevant".