Corpor-Air Inc. v. The Queen, 2007 DTC 841, 2006 TCC 75 -- summary under Subsection 256(5.1)

The taxpayer was found to be subject to the de facto control of the husband of the individual who was its sole director, shareholder and officer given that the companies that were virtually its only source of revenue (in the form of management fees) were controlled by her husband, the taxpayer did not own any capital assets (other than non-interest bearing advances owing to it by that group of companies), its only capital was non-interest bearing advances that had been made to it by that group of companies and inferences to be drawn from the unsatisfactory nature of her testimony and the failure to call her husband as a witness.