Mulligan v. R., 99 DTC 951, [1999] 3 CTC 2092 (TCC) (Informal Procedure) -- summary under Dividend

Before going on to find that the taxpayer had received a dividend notwithstanding the absence of formal corporate action by the directors (i.e., she and her husband), Rip TCJ. stated (at p. 957) that "the state of corporate law today is that the formalities required by statute or the articles of the corporation may be bypassed if the shareholders or directors who have the power to authorize the action unanimously approve of the action".