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Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) Quaere whether beneficiary is beneficial owner (pp. 20:7-8) Some commentators argue that a beneficiary of a trust is the beneficial owner of trust property, while others consider a beneficiary to have only a personal right to compel the trustee to administer a trust pursuant to the terms of the trust agreement. [fn 30: … (2003) Canadian Tax Journal 311-54 … 401-53] [T]here will be a bare trust where the trustee—in all dealings relating to the trust property—has no discretion and is subject to the control of another person. ...

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[fn 39: S & D International Group Inc. v. Canada (Attorney General), 2011 ABQB 230, at paragraph 106.] ... At issue was the wording of a restrictive covenant in an employment contract between Shafron and KRG Insurance Brokers – specifically, the interpretation of the ambiguous phrase "Metropolitan City of Vancouver. ... In order to get rectification it is necessary to show that the parties were in complete agreement on the terms of their contract, but by an error wrote them down wrongly; and in this regard, in order to ascertain the terms of their contract, you do not look into the inner minds of the parties – into their intentions – any more than you do in the formation of any other contract. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership Quaere whether beneficiary is beneficial owner (pp. 20:7-8) Some commentators argue that a beneficiary of a trust is the beneficial owner of trust property, while others consider a beneficiary to have only a personal right to compel the trustee to administer a trust pursuant to the terms of the trust agreement. [fn 30: … (2003) Canadian Tax Journal 311-54 … 401-53] [T]here will be a bare trust where the trustee—in all dealings relating to the trust property—has no discretion and is subject to the control of another person. ...

.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission ...

.-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Includes (at pp. 751-754) a discussion of the Clayton rule. ...

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", Tax Notes International, 16 August 2004, p. 631-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Discussion of Snow White Productions Inc. v. ...

Arnold, "Timing and Income Taxation: The Principles of Income Measurement for Tax Purposes", Canadian Tax Paper, No. 71, Canadian Tax Foundation, July 1983-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt See chapter 3 entitled "Cash Basis Accounting: The Concepts of Receipt and Payment". ...