Bessette – Quebec Court of Appeal uses the “sham” word in denying fees paid to a professional services company

A dental practice paid 70% of its revenues to a professional services company which had no employees and purchased no supplies. In dismissing the taxpayer’s appeal, Gouin JCQ stated that "it is necessary to prove that the management expenses constitute genuine expenses and not a sham in the sense that the concluded agreements represented genuine transactions between the parties."

Neal Armstrong. Summary of Bessette v. ARC (Quebec Revenue Agency), 2014 QCCQ 4329 under s. 18(1)(a) – income producing purpose.