Romkey v. Canada, 2000 DTC 6047 (FCA) -- summary under Subsection 74.1(2)

Trusts, that were established for the taxpayers' children, subscribed for non-voting common shares of the corporation for a nominal amount. The Court affirmed the finding of the trial judge that s. 74.1(2) applied in the absence of being satisfied that the trusts had paid for the shares issued to them and in light of the broad meaning accorded to the concept of a transfer of property in the Kieboom case.