Thibault v. R., 99 DTC 489, [1999] 2 CTC 2645 (TCC) -- summary under Tax Avoidance

In addition to selling his shares of a company for $100,000, it was agreed that the company would hire a corporation controlled by the taxpayer as a consultant for a period of five years for $150,000 payable in 60 consecutive equal instalments. Lamarre Proulx TCJ. found that the contract for services in fact gave rise to additional proceeds of disposition notwithstanding a judgment of the Superior Court of Quebec in which was found the contract for services was valid rather than a simulation representing the price for shares.