The appellant corporation was incorporated solely to purchase and hold land as a mandatary for two other companies.
The Minister of Revenue assessed the value of the land as 'paid-up capital' under the Corporation Tax Act and imposed a tax.
The Supreme Court of Canada held that the appellant acted as a nominee (prête-nom) and its obligation to the true owners was not a debt.
Therefore, the value of the land did not constitute paid-up capital, and the assessment was vacated.
