Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62 -- attach -- Ownership
test of beneficial ownership
Ownership
21 June 2017 External T.I. 2017-0687961E5 - Principal residence exemption and farm property -- attach -- Ownership
purported retention of beneficial ownership of portion of non-severable parcel of land was ineffective
Mady v. The Queen, 2017 TCC 112 -- attach -- Ownership
wife and children did not acquire beneficial interest in shares the taxpayer was to transfer to them, under tax plan, until the share transfer occurred
5 November 2014 External T.I. 2014-0521891E5 F - Résidence principale et copropriété -- attach -- Ownership
whether a tacit co-ownership agreement is respected is a private law issue
9 December 2016 External T.I. 2016-0639481E5 - Specified foreign property-jointly held property -- attach -- Ownership
"property of" a taxpayer applies to a beneficial (or legal?) co-owner who made no financial contribution
7 October 2016 APFF Roundtable Q. 10, 2016-0652931C6 F - Bien agricole admissible-saisine par succession -- attach -- Ownership
estate owns its property
Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151 -- attach -- Ownership
beneficial owner did not transfer property risk
Metropolitan Toronto Police Widows and Orphans Fund v. Telus Communications Inc., [2003] OJ No 128, 30 BLR (3d) 288, 2003 CanLII 25909 (ON SC) -- attach -- Ownership
true sale to securitization trust rather than secured loan
Collins v. The Queen, 96 DTC 1034 (TCC) -- attach -- Ownership
ownership means beneficial ownership
Bueti v. The Queen, 2015 DTC 1213 [at at 1374], 2015 TCC 265 -- attach -- Ownership
residuary beneficiary had no ownership of estate property
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