reason

By services, 20 August, 2023

The appellant was assessed under s. 103(1). A representative of the appellant (Mr. Thompson, who wholly-owned it) refused to answer questions posed on his examination for discovery that were designed to elicit the reason or purpose for which various transactions were engaged in by the appellant and other companies in the group.

After referring to the “principal reason” test in s. 103(1), Sommerfeldt J stated (at para. 42):