http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/72238/index.do 
Baker v. The Queen (June 24, 2014 – 2014 TCC 204) was an odd case where the taxpayer allegedly purchased shares in his RRSP at an inflated value and CRA taxed him on the inflated amount pursuant to subsection 146(9) of the Income Tax Act:
Where disposition of property by trust
(9) Where in a taxation year a trust governed by a registered retirement savings plan
(a) disposes of property for a consideration less than the fair market value of the property at the time of the disposition, or for no consideration, or
(b) acquires property for a consideration greater than the fair market value of the property at the time of the acquisition,
the difference between the fair market value and the consideration, if any, shall be included in computing the income for the taxation year of the annuitant under the plan.
What is unusual is that he appears to have done this in conjunction with a tax objectors group:
[46] The CRA auditor testified that he learned that the Cancun seminar attended by the Appellant was sponsored by an organization known as the Institute of Global Prosperity (“Global Prosperity”). This organization promotes an aggressive anti-tax philosophy through audio and in-person seminars, the latter typically held in offshore locations. According to the witness, Global Prosperity requires its clients to purchase the audio seminar package as a precondition to attendance at an offshore conference. The cost is approximately $1,500 for six audio disks. The CRA auditor testified that he listened extensively to the audio seminars and prepared a written summary of the highlights of the seminars. His written summary was presented as part of the Appellant’s read-in evidence. On page 1 of his report, he summarizes his findings as follows:
The gist of the Global Prosperity Level 1 education audio tape set is to convince the listener that income tax legislation in Canada and the U.S.A. is not constitutional (it has never been passed into law) and thus the payment of income tax is voluntary. It encouraged listeners to discard their social insurance or social security numbers, driver’s licenses, and government-issued currency, to become detached from all government programs including RRSP’s and health care, and to move title to their worldly possessions to offshore trusts. These offshore trusts should not be registered in their own names, but registered to IGP personnel with an agency agreement in place allowing the individual to use the property they purchased. As the only “business” of the trust is to protect the personal assets of the individual, the individual can now claim personal living expenses as business expenses, or so they claim. The tape package insists that the supply of money in Canada and the U.S.A. is controlled by the so-called “international banking-cartel” rather than the Bank or Canada or Federal Reserve.
[47] In light of the above, I believe that the Appellant was well aware of the subject matter of the seminars when he signed up for the seminar, but chose to downplay this fact in order to conceal the reason for the purchase of Kelso Securities by the RRSP.
The parties were at odds as to whether subsection 146(9) required proof of an attempt to avoid tax. The court did not find it necessary to rule on the matter since it did not accept Mr. Baker’s evidence that the transaction was not motivated by tax avoidance:
[38] It is apparent from the above that Mr. Graschuk understood that he was being asked to confirm that the Minister would not seek to defend its assessment using the general anti-avoidance rule found in section 245 of the Act. I cannot construe these remarks as an admission that the Respondent was prepared to abandon the assumptions in paragraphs 9a) and b) of the Reply to the effect that the Kelso Securities were promoted and marketed for the purposes of an arrangement which would allow investors such as the Appellant to gain control of their RRSP funds offshore while avoiding tax on the withdrawal.
[39] The Appellant’s counsel also insists that the Appellant’s evidence contradicts these assumptions such that the Minister bears the burden of showing that they are true. For the reasons outlined below, I attach no weight to the Appellant’s evidence. Therefore, the assumptions stand. In any event, I believe that the evidence shows, on a balance of probabilities, that the Appellant acted in a complicit manner in giving his approval to the transaction because he was led to believe he would receive a collateral benefit. Therefore, I can decide this appeal without choosing between the two interpretations of subsection 146(9) of the Act presented by the parties.
As a result the appeal was dismissed with costs to the respondent.