R. v. Campbell, 80 DTC 6239, [1980] CTC 319, [1980] 2 SCR 256 -- summary under Tax Avoidance

By services, 28 November, 2015

The fact that the taxpayer surgeon responded to regulations, requiring that OHIP be billed in the name of an individual doctor, by billing for surgical services he had performed as employee of a private hospital owned by him, then assigning those fees to the hospital, did not mean that the hospital was engaged in the illegal practice of medicine. The employment contract between the surgeon and the hospital was not illegal, and the assigned fees had been earned by the hospital, not by him. [C.R.: 18(1)(a) - "Related Companies"]

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