Can a person be considered a de facto director of a company?

Canada (Federal), Canada

The following excerpt is from MacDonald v. The Queen, 2014 TCC 308 (CanLII):

In Perricelli v. R., 2002 G.T.C. 244, Justice Miller notes that the determining factor in concluding that a person could not be considered a de facto director was that the person "did not believe he is a director and he never thought he had any authority to advise, influence or control, the management or direction of the company".

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