Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260 -- summary under Subsection 256(6)

In rejecting a submission of the Crown that a U.S. corporation ("Silicon U.S.") had de facto control of the taxpayer and finding that the taxpayer was a Canadian-controlled private corporation, Sexton J.A. noted (at p. 7121) that the facts alleged by the Crown simply demonstrated that Silicon U.S. was protecting its interests as a lender to the taxpayer.