W. B. Pletch Company Limited v. The Queen, 2006 DTC 2065, 2005 TCC 400 -- summary under Personal Services Business

The taxpayer was owned by an individual ("Pletch") and his wife. Pletch served as the president and then as vice-president and director of a company ("Thyssen"), and the taxpayer provided the services of Pletch to Thyssen for management fees. In finding that the taxpayer carried on a personal services business, Hershfield J. found that (given the flexibility of some of the arrangements between Thyssen and Pletch), some of the services of Pletch provided by the taxpayer to Thyssen could be characterized as advisory services, there was no allocation of the compensation paid to the taxpayer wearing its "advisory hat" and "executive hat", and that the services of the taxpayer had been merged into one source of income viz., compensation for performing the role of senior executive.