reasonable

The taxpayer and another wholly-owned subsidiary (“Taylor”) of the same corporation (“PIRG”) were the 5% and 95% partners, respectively, of a partnership, with an October 31 year end, which was engaged in developing a Vancouver condominium project. In October 2006, after virtually all of the profits from the development had been realized, PIRG transferred the shares of Taylor to a “Lossco” with which it dealt at arm’s length (“Meston”), with Taylor then being wound-up into Meston.

The taxpayer did not file income tax returns for the 1988 to 2003 taxation years on the basis that as he owed no tax, this was unnecessary. Thus, when he made RRSP contributions in 2003 and 2004, he had not received any recent Notices of Assessment and, thus, no details of his unused RRSP contribution room – which, in fact, had been reduced to near zero as a result of his and his employer’s contributions to a registered pension plan.

The appellant ("Sun Life"), whose principal business was the sale of financial products, subleased space in its various office buildings to independent contractors who also sold Sun Life financial products, at rents that also were intended to capture costs of the building common areas.