Collins v. The Queen, 96 DTC 1034 (TCC)

Bowman TCJ. stated (at p. 1037) that he agreed with the proposition that "ownership for purposes of the Income Tax Act means beneficial ownership."

Before rejecting a submission that the taxpayer had held half of his shares of a private company on a resulting trust for his wife, Bowman TCJ....

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Before rejecting a submission that the taxpayer held half of his shares of a private company on a constructive or resulting trust for his wife,...

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