- Parties: The appellant was Gestion M-A Roy Inc. The respondent was Sa Majesté le Roi.

- Subject Matter: The appellants held six life insurance policies with investment accounts valued at $20 million. The policies insured the life of the appellants’ majority shareholder. The revocable beneficiary, which was an operating company majority-owned by the appellants’ majority shareholder, paid the insurance premiums. The Minister of National Revenue issued to the appellants assessments for the 2014, 2015, 2016, and 2017 taxation years. The Tax Court of Canada upheld the assessments. The Tax Court determined that the premium payments made by the revocable beneficiary relating to the insurance contracts held by the appellants constituted a benefit under ss. 15(1) and 246(1) of the Income Tax Act, 1985. The appellants challenged the Tax Court’s decision.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal with costs. The appeal court essentially agreed with the Tax Court’s approach. The appeal court adopted the Tax Court’s analysis of the issues and its legal reasoning relating to these issues. The appeal court saw no error in the Tax Court’s determination of the value of the benefit for the subject years, given its conclusion as to the characterization of the benefit.

- Date: The hearing was set on Jan. 18, 2024. The court released its decision on Jan. 18, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.