ascribed zero value in the sale, including the BVI standing timber,
the BVI standing timber receivables, the wood log receivables and
the wood log deposits. The trial judge found that, at the time of
trial, there had been no recoveries on, or any further payments in
respect of, those assets: at paras. 89-96.
 The total net recoveries from the sale of assets of SFC’s
subsidiaries was $438.5 million.
(3) The trial judge’s damages award
 The trial judge approached causation on the basis that the
“but for” causation test was to be applied in a common sense, robust
fashion; that causation could be inferred from evidence that connected the wrongdoing to the injury; and that inferences could be
drawn against a defendant found liable for fraud or breach of fiduciary duty who did not provide credible alternative causes for the loss.
 The trial judge’s factual findings about causation can be
summarized as follows. Between 2004 and 2010, SFC raised in
excess of $2.9 billion in Canada’s debt and equity markets, based
on the appellant’s fraudulent misrepresentations of the existence
and value of assets. But for the appellant’s deceit, SFC would
never have undertaken obligations of this magnitude to lenders
and shareholders, nor would it have entrusted the money it
raised to the appellant and his management team. The appellant
directed much of the money raised towards fictitious or over-valued lines of business, engaged in undisclosed related-party
transactions and funneled funds into entities he secretly controlled. This conduct, and the consequences of its discovery,
ultimately caused the collapse of SFC. The trial judge found that
SFC had suffered losses directly related to the appellant’s fraud
and breach of fiduciary duty.
(b) Measurement of damages
 The trial judge referred to the measure of tort damages for
deceit and to the principles of equitable compensation. He accepted
that the proper approach to measuring SFC’s loss was the primary
approach put forward by the respondent’s expert, Peter Steger.
 Steger’s primary approach began with the $2.9 billion SFC
raised in the debt and equity markets between 2004 and 2010.
Subtracting the share and debt issue costs and principal debt
repayments made by SFC, he calculated the net cash available to
SFC from these capital raises as $2.588 billion. To this, Steger
added a proxy for the minimum return that SFC should have