The Federal Court of Appeal gave its decision on 23 June 2007 in the case of Mil (Investments) S.A. v. Her Majesty the Queen. Details of the decision are summarized below. (a) Facts. An individual, Jean-Raymond Boulle, acquired shares of Diamond Field Resources Ltd. (DFR), a Canadian public company. The shares were transferred to the Appellant, a newly incorporated Cayman Islands company, wholly owned by the taxpayer. DFR discovered a major deposit of nickel, copper and cobalt in Canada, in which several mining companies were interested. As a result, the share price increased substantially. In 1995, the Appellant exchanged shares...