MFC Bancorp Ltd. v. R., 99 DTC 905, [1999] 4 CTC 2468 (TCC) -- summary under Paragraph 251(1)(c)

A transfer by the taxpayer of its interest as lessor in mining concessions and railway rights-of-way to a corporation ("CJC") in which a subsidiary of the taxpayer had a beneficial 37% interest was found to be a non-arm's length transaction given that the boards of the taxpayer and CJC had mostly overlapping directors and that one of those directors had determined that the transfer should occur for consideration that was 20% less than the appraised value of the leasehold interest.