Subsection 15(1)

sale of newly constructed homes to shareholders at cost plus a gross margin did not avoid shareholder benefit issues

no benefit conferral where corporation pays premiums on policy on life of its shareholder of which it is the policyholder and beneficiary

s. 15(1) might apply where a corporation pays the premiums on a segregated fund insurance policy under which its shareholder or spouse is the beneficiary

use of yacht for marketing involving socializing was not a shareholder benefit

benefit from payment by corporation of life insurance premiums on policy of which shareholder’s spouse is the beneficiary is based on the premiums so paid

s. 15(1) could apply where corporate funds used to acquire non-participating preferred shares

misallocation shareholder benefit could arise if corporation pays premiums for its critical illness policy and sole shareholder pays for rider entitling him to premium refunds

factors relevant to determining FMV of life insurance policy

where FMV of pre shares received on estate-freeze s. 51 exchange was less than that of the exchanged common shares, CRA would apply s. 51(2), not s. 15(1)

application of the Chopp principle that a s. 15 benefit is conferred where the shareholder ought to (but did not) know of the benefit