Hargreaves Property Holdings Ltd v Revenue And Customs, [2024] EWCA Civ 365 -- attach -- Ownership
beneficial ownership/ entitlement means having the benefits of ownership
Ownership
Greenway v. Canada, 96 DTC 6529 (FCA) -- attach -- Ownership
taxpayer was beneficial owner of MURB investment notwithstanding defects in agreement to acquire title from title holder
Hudson’s Bay Company v. OMERS Realty Corporation , 2016 ONCA 113 -- attach -- Ownership
general partner holds and controls the limited partnership property
Re Lehndorff General Partner Ltd. (1993), 9 BLR (2d) 275, 17 C.B.R. (3d) 24, [1993] O.J. No. 14 ( Ont. Gen. Div.) -- attach -- Ownership
limited partners do not have any independent ownership rights in partnership property
9154-6093 Québec Inc. v. Agence du revenu du Québec, 2023 QCCQ 10241 -- attach -- Ownership
property was transferred to shareholders as nominees in light inter alia of consistent reporting of the transferor as the continued actual owner
3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 3, 2023-0976921C6 F - CELIAPP - Acquisition d'une quote-part d'une habitation admissible / FHSA - Acquisition of a share of a qualifying home -- attach -- Ownership
reference to acquiring a qualifying home includes acquiring a co-ownership interest
2 November 2023 APFF Roundtable Q. 10, 2023-0993641C6 - APFF - Congrès 2023 Q.10 disposition de cryptomonnaie -- attach -- Ownership
bitcoin platform likely acquired ownership of bitcoin deposited with it
23 March 2023 GST/HST Ruling 244917 - GST/HST implications of constructing a laneway house -- attach -- Ownership
each joint tenant owns the entire property
15 November 2022 GST/HST Ruling 231643 - Partnership eligibility to claim input tax credits on the construction of houses for sale -- attach -- Ownership
CRA considers real property to belong to the registered owners unless beneficial ownership by a partnership can be demonstrated
Emergis Inc. v. Canada, 2023 FCA 78 -- attach -- Ownership
s. 20(12) did not displace the general rule that the assets and income of a corporation are not the assets and income of its shareholders
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