"[FN 2] The argument is that the benefit under subsection 15(1) of the Act should be reduced by the liability under section 160 of the Act because the appropriation carries with it liability under that section. In other words, the value of the benefit received by the shareholders under subsection 15(1) is the net amount. This is analogous to the situation where real estate is encumbered with a mortgage lien. In that particular case, the benefit is the net market value of the property after accounting for the mortgage lien."
Budwal v. The Queen, 2014 TCC 370 (Hogan)