CRA accepts that no nominee agreement is required if the facts are obvious

Title to daughter’s home was acquired in her mother’s name due to lender requirements, but daughter made all the mortgage payments.  CRA accepted that daughter was the beneficial owner notwithstanding the absence of a nominee agreement or bare trustee declaration.  See also Fourney and Peragine.

Neal Armstrong.  Summary of 22 November 2013 T.I. 2013-0511771E5 under s. 104(1).