The appellant ("Prescient") had served as an intermediary in an asset sale, and thereby attempted to confer on private individuals similar tax advantages to those enjoyed by charitable foundations. In the course of the asset sale, the taxpayer and several other charitable foundations acquired 95% of the shares of a farm corporation, and donated the farm assets to another foundation.
In the course of affirming the Minister's decision to revoke Prescient's charitable registration (see above fore details), Mainville JA noted that Prescient's dealings with the farm corporation did not qualify as a "related business activity," as "it was known, at the outset of the activity, that its outcome would be a major loss" because the farm corporation's assets were going to be donated (para. 40).