In what circumstances will a father be held to receive his son's shares as a gift?

In Bochurka v. Bochurka, 2009 MBQB 295, the son, who received shares as a result of an estate freeze, was held to receive them as a gift. However, the evidence pointing to a gifting transaction was much stronger, including evidence of an extremely close familial relationship, evidence of many types of gifts between father and son and evidence from the mother, who was the corporate secretary at the relevant time, that the son had never paid for the shares. Finally, the documentary evidence was more equivocal in that the son did not sign the subscription for the shares. These are very different facts than in this case.