I don't think Curtain-Hammett is appropriate description here b/c Curtain-Hammett describes the case where we have two rapidly interconverting species, each of which can irreversibly go on to products. From the delta G's invovled we can then predict the product ratio.
However in this case only one of the species (the ylide) involved can go on irreversibly to form products (since the KO
tBu can't irreversibly form a product with the cabonyl). So in the end it comes down to Le Chatlier's principle b/c we're only applying a stress to one side of the chemical equation.
In the end though, I believe I understand what your saying and I don't mean to be splitting hairs
. I'm just curious as to what you think about my take on the Curtain-Hammett.