Ceco Operations Ltd. v. The Queen, 2006 DTC 3006, 2006 TCC 256 -- summary under Substance

In finding that a transfer by the taxpayer of business assets to a partnership in consideration for partnership units and non-units consideration ("boot") should not be recharacterized as a transfer by the taxpayer solely for boot, notwithstanding that the partnership thereafter indirectly distributed cash to the holding-company shareholders of the taxpayer by subscribing for preferred shares, Bonner J. noted that cases cited to him involving a preference for the supposed substance of transactions over their form were contrary to the approach taken by the Supreme Court of Canada in Shell Canada Ltd. v. The Queen.