Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 SCR 496 -- attach -- Ownership
the shares of a subsidiary of a corporation are not owned “indirectly” by the shareholders of that corporation
Ownership
15 December 2003 External T.I. 2003-0182855 - Fiducie pour Loi au Quebec -- attach -- Ownership
sole beneficiary of Quebec trust is the beneficial owner of its property
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- attach -- Ownership
leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise
18 July 2022 External T.I. 2021-0887121E5 - Feeder Cattle Loan Guarantee Program -- attach -- Ownership
members of a corporate co-op likely were the beneficial owners of the co-op cattle inventory notwithstanding the documentation’s contrary label
Chan v. The Queen, 2022 TCC 87 (Informal Procedure) -- attach -- Ownership
taxpayer did not have the beneficial ownership of a bank account which he did not use
9 May 2022 Internal T.I. 2018-0790251I7 - 45(2) election and beneficial ownership -- attach -- Ownership
a spouse could be the beneficial owner even though she did not contribute to the property's purchase / owner means beneficial owner
Canada (National Revenue) v. Shaker, 2022 FC 407, 2022 FC 408 -- attach -- Ownership
property held in trust cannot be said to belong to the trustee
Geraint Thomas, Alastair Hudson, "Chapter 7: The Nature of a Beneficiary’s Interest", The Law of Trusts,” Oxford University Press, 2004 -- attach -- Ownership
16 May 2005 Internal T.I. 2005-0119061I7 F - Montant d'aide-actions -- attach -- Ownership
transfer of the economic benefit of copyright entails transfer of its ownership
Canada v. Canada North Group Inc., 2021 SCC 30, [2021] 2 SCR 571 -- attach -- Ownership
Crown deemed trust interest did not have the attributes of beneficial property ownership
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