Davidson v. R., 99 DTC 933, [1999] 3 CTC 2159 (TCC) -- summary under Paragraph 15(2.4)(f)

Before finding that a loan made by a family company to the taxpayer to finance the acquisition of a home satisfied the requirements for bona fide arrangements for repayment (based on evidence that the taxpayer and her husband intended that the loan would be repaid through the proceeds of a dividend to be made within five years of the date of advance). Bowie TCJ. indicated that there was no requirement for an arrangement to be contractually binding (the plain meaning of the word "arrangement" indicated as much), that there was no requirement for repayment on a date certain and that evidence that the payment was not made in accordance with the arrangement (as was the case here) was relevant to the issue of bona fides but was not conclusive on the issue.