Ault v. Canada (Attorney General), 2011 ONCA 147, an important case on negligent misrepresentation generally, restates the 'but for' test for causation well:
[44] The basic test for determining causation in cases of negligence is the "but for" test. The plaintiff bears the burden of showing that "but for" the negligent act or omission of the defendant the injury or harm would not have occurred.
[45] The "but for" test recognizes that compensation for negligent conduct should only be made where there is a substantial connection between the injury and the defendant's conduct: Resurfice Corp. v. Hanke, [2007] 1 S.C.R. 333, at para. 23. In assessing the issue of "substantial connection", courts consider whether the damages claimed were a reasonably foreseeable result of the defendant's negligence. In cases where there is not a substantial connection between the damages and the negligence, the damages are said to be too remote for recovery.
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