Transalta Corporation v. The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86 -- summary under Incurring of Expense

Margeson J. accepted (at para. 101) that the stated capital (equal to fair market value) of shares which the taxpayer issued in payment of bonuses under its Performance Share Ownership Plan represented the expenditure made by the taxpayer on the bonuses. He rejected the Minister's position (at para.93) "that the Appellant incurred no expense in issuing shares under the PSOP."