Canada c. Roll, 2001 DTC 5055 (FCA) -- summary under Paragraph 153(1)(a)

Given that he had made payments of remuneration to employees as a bare trustee for the corporation and the taxpayer, who was an employee of a corporation in financial difficulty, was persuaded by the president to receive deposits of the net payroll obligations of the corporation to his own bank account and to then disburse those amounts to the employees and that the decision to make payments of the net salaries of the employees was that of the principals of the corporation alone, it followed that the taxpayer was not within the scope of s. 153(1), 153(1.3) or 227(5).