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The Queen, 2019 TCC 265-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership markers of possession, use and risk applied in ascertaining beneficial ownership Before finding that there had been a transfer to the taxpayer of ½ of the beneficial ownership of the family home for s. 160 purposes from her husband (rather than her having been the full beneficial owner all along), MacPhee J adopted (at para. 24) a previous judicial formulation of the concept of beneficial ownership, viz: The primary attributes of beneficial ownership include possession, use and risk. ...

Boivin JA stated (at para. 7): [These] remarks … were ill-considered. ...

. … Canada interprets the legislature’s use of the words “held in trust” as necessarily requiring the existence of a private law trust relationship. ...

To address increasing mobility issues of his wife, the taxpayer replaced these with a deck with a 5-foot wide stairway and aluminum railing – and claimed the $10,000 home accessibility tax credit. ...

. … In default of being able to speak of permanent physical integration, one can certainly speak of a functional integration as the plaintiff could not carry out its operations in the Great North without the Econox. ...

As this Court has reiterated on numerous occasions, this approach requires that the words of the statute be read “in their entire context and in their grammatical and ordinary sense harmonious with the scheme of the Act, the object of the Act, and the intention of Parliament” …. ...

Profit- Real Estate subdivision of rental property prior to sale of individual units did not detract from capital account treatment Three individuals who had purchased an eight-unit rental property in co-ownership, determined around 4 ½ years later to sell the property due to a change in personal circumstances of one of them. ...

Agence du revenu du Québec, 2019 QCCQ 7377-- summary under Subsection 13(4) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(4) departure from written terms of lease to find that a rental property was used principally in the active business of a related person One of the exceptions from the rule that a rental property cannot qualify as a “former business property” for purposes of the replacement property rules in ITA ss. 13(4) and 44 references the situation of a “property … leased by the taxpayer to a person related to the taxpayer and used by that related person principally for any other purpose.” ...

Krumm, IAC and its agents could each be considered to be a tax shelter “promoter”, as defined in subsection 237.1(1) …. ...

After finding that this agreement bound the Crown insofar as the first taxation year was concerned, Woods JA noted that the Tax Court order giving effect to the agreement had the likely effect of not only reducing CBS’ tax for its taxation year ended March 7, 2007 but of also increasing tax for the subsequent taxation year – and then addressed the issue as to whether such an increase in tax for one of the taxation years was permissible under the ITA, and stated, in the affirmative (paras. 44-45): It is significant that, in both Harris and Last, it was the Crown and not the taxpayer that sought an increase in tax. ...