- Parties: The appellants were 2093271 Ontario Inc., 2013674 Ontario Inc., Columbia Highrise Windows and Railings Inc., and Columbia Highrise Windows Group Inc. The respondent was His Majesty the King.

- Subject Matter: Ron Bonin, CEO and sole manager of each of the appellants, incorporated the appellants to carry on the business of window and railing manufacturing and installation. The appellants claimed deductions for management fee expenses. Reassessments were made under the Income Tax Act, 1985. The appellants appealed from these reassessments. The Tax Court of Canada dismissed these appeals. The Tax Court held that there were no written or oral agreements for the provision of management services and that the tax advisor determined the amounts yearly charged based on the amount of the paying company’s income and not based on any measurable factors. The appellants challenged the Tax Court’s judgment.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal with costs. The appeal court saw no reviewable error in the Tax Court’s determinations that the amounts claimed were not deductible, that the appellants were liable for gross negligence penalties, and that the Minister validly opened up the taxation years in question.

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

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

- Amount: No financial award was specified.