Gestion Léon Gagnon Inc. c. La Reine, 2007 DTC 267, 2006 TCC 682 -- summary under Subsection 15(1)

No s. 15(1) benefit was conferred on the taxpayer when a corporation, ("CFIC") whose common shares were owned as to 55% by the taxpayer's sole shareholder and as to 45% by his wife, issued preferred shares to the taxpayer with a redemption amount of $1,000 per share and a subscription price of $1 per share. The preferred shares were redeemed a month later in order to extract funds from CFIC). Lamarre Proulx J. found that subsection 15(1) did not contemplate that there would be a benefit conferred by virtue only of shares being issued with a high redemption amount given that their redemption would be deemed to give rise to a dividend under subsection 84(3).