Before going on to find that amounts paid by the taxpayer to its non-resident shareholder and to a non-resident company controlled by him were reasonable in amount, and that their payment did not give rise to the conferral of any benefit, Bowman TCJ. noted that, in the case of the payments made to the non-resident company, the benefit under s. 214 was assessed on the individual rather than his non-resident company and stated (at p. 1770):
"I should have thought as a matter of common sense that the conferral of a benefit on a corporation, all of the shares of which are owned by a taxpayer, would constitute a benefit conferred on the taxpayer. It increases the value of the taxpayer's shareholding in the corporation that receives the benefit and allows the corporation to make payments to the shareholder that it could not otherwise do.