See Also
Sutter Salmon Club Ltd. v. The Queen, 2004 TCC 443
The non-resident shareholders of the appellant, which was an extra-provincial corporation carrying on business in New Brunswick, engaged in a practice of making contributions of capital to the appellant to fund the costs incurred by it in operating a fishing lodge. For a fee, each shareholder used the lodge for one week a year.
S.140 did not apply to the appellant given that it did not issue shares in consideration for the capital contributions nor was there any evidence that payment of the capital contributions by the shareholders was a condition of the shareholders obtaining membership in the taxpayer (they already were shareholders).