23 September 2025 External T.I. 2025-1064831E5 - "Specified foreign property" under ss. 233.3(1) -- attach -- Ownership electronic certificate to allocated or unallocated bullion entailed beneficial ownership of the indicated quantity Read more about 23 September 2025 External T.I. 2025-1064831E5 - "Specified foreign property" under ss. 233.3(1) -- attach -- Ownership
20 November 2023 External T.I. 2022-0937331E5 - New Housing Model and Beneficial Interest -- attach -- Ownership tenant under a rent-to-own program did not have all the basic attributes of ownership and, thus, was not the beneficial owner Read more about 20 November 2023 External T.I. 2022-0937331E5 - New Housing Model and Beneficial Interest -- attach -- Ownership
Canada v. LBL Holdings Limited, 2025 FCA 186 -- attach -- Ownership sale of products to a reserve Indian with a flash resale to a non-Indian ultimate customer resulted in ownership passing to the Indian on the reserve Read more about Canada v. LBL Holdings Limited, 2025 FCA 186 -- attach -- Ownership
31 October 1988 Income Tax Severed Letter 7-3237 - [Tax Treatment of Silver Certificates on Becoming a Resident of Canada] -- attach -- Ownership holder of silver or gold certificates entitled to treat themselves as owners of the bullion for s. 47 purposes notwithstanding that no in rem right Read more about 31 October 1988 Income Tax Severed Letter 7-3237 - [Tax Treatment of Silver Certificates on Becoming a Resident of Canada] -- attach -- Ownership
10 September 1999 Internal T.I. 9911747 F - ACTIONNAIRES D'UNE SOCIÉTÉ -- attach -- Ownership incorrect disclosure to regulatory body did not affect the ownership of shares of a management services corporation through the two architects’ respective holding companies Read more about 10 September 1999 Internal T.I. 9911747 F - ACTIONNAIRES D'UNE SOCIÉTÉ -- attach -- Ownership
17 June 2025 STEP Roundtable Q. 2, 2025-1051581C6 - Succession of Family Business -- attach -- Ownership trustee are not owners of shares in the corpus Read more about 17 June 2025 STEP Roundtable Q. 2, 2025-1051581C6 - Succession of Family Business -- attach -- Ownership
12 March 2025 External T.I. 2025-1053231E5 - Effects of a Power of Attorney on TOSI -- attach -- Ownership granting power of attorney over shares did not divest the grantor of their ownership Read more about 12 March 2025 External T.I. 2025-1053231E5 - Effects of a Power of Attorney on TOSI -- attach -- Ownership
8 November 2000 Internal T.I. 2000-0025167 F - RECONNAISSANCE DU REVENU D'INTERET -- attach -- Ownership interest on tax refund was income to the insurer who had been subrogated to the taxpayer’s claim against CRA Read more about 8 November 2000 Internal T.I. 2000-0025167 F - RECONNAISSANCE DU REVENU D'INTERET -- attach -- Ownership
9 July 2024 Internal T.I. 2023-0976691I7 - Film Tax Credit and Alter Ego Trust -- attach -- Ownership the property of an alter ego trust “belonged” to its sole trustee and life beneficiary rather than to the trust Read more about 9 July 2024 Internal T.I. 2023-0976691I7 - Film Tax Credit and Alter Ego Trust -- attach -- Ownership
Magren Holdings Ltd v. Canada, 2024 FCA 202 -- attach -- Ownership RRSP trust transferred the ownership of the income fund units in which it transacted Read more about Magren Holdings Ltd v. Canada, 2024 FCA 202 -- attach -- Ownership