beneficial ownership

Summary Under
Tax Topics - General Concepts - Ownership
electronic certificate to allocated or unallocated bullion entailed beneficial ownership of the indicated quantity

The resident taxpayer, like other clients of a corporation resident in Canada, purchased Holdings evidenced by electronic records provided online...

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Words and Phrases
beneficial ownership
Summary Under
Tax Topics - General Concepts - Ownership
tenant under a rent-to-own program did not have all the basic attributes of ownership and, thus, was not the beneficial owner

Under a program for a prospective homebuyer to start living in a residence while making contributions towards potential ownership of the...

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Words and Phrases
beneficial ownership

Hargreaves Property Holdings Ltd v Revenue And Customs, [2024] EWCA Civ 365 -- summary under Ownership

Full Title
Hargreaves Property Holdings Ltd v Revenue And Customs, [2024] EWCA Civ 365
Summary Under
Tax Topics - General Concepts - Ownership
beneficial ownership/ entitlement means having the benefits of ownership

Whether the UK taxpayer (“Hargreaves”) was liable for failure to withhold UK tax on interest paid by it to a non-arm’s length UK company...

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Words and Phrases
beneficial ownership
equitable ownership
beneficial entitlement
Summary Under
Tax Topics - General Concepts - Ownership
members of a corporate co-op likely were the beneficial owners of the co-op cattle inventory notwithstanding the documentation’s contrary label

As an economic matter, members of a feeder cattle finance cooperative established under the Co-operative Corporations Act used money borrowed on...

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Words and Phrases
beneficial ownership legal ownership
Summary Under
Tax Topics - Income Tax Act - Section 45 - Subsection 45(2)
spouse could be a beneficial co-owner of the converted home (even though her husband funded its purchase) so that both must elect

Spouses purchased a home in 2006 which they used as their primary residence until 2015, when they moved out and started renting it out. Although...

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Words and Phrases
beneficial ownership

Canada (National Revenue) v. Shaker, 2022 FC 407, 2022 FC 408 -- summary under Ownership

Full Title
Canada (National Revenue) v. Shaker, 2022 FC 407, 2022 FC 408
Summary Under
Tax Topics - General Concepts - Ownership
property held in trust cannot be said to belong to the trustee

CRA obtained an interim order to charge the interest of Mr. Shaker, as one of the trustees of a trust (the “VSI Trust”) for a Toronto property...

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Words and Phrases
beneficial ownership

Canada v. Canada North Group Inc., 2021 SCC 30, [2021] 2 SCR 571 -- summary under Ownership

Full Title
Canada v. Canada North Group Inc., 2021 SCC 30, [2021] 2 S.C.R. 571
Summary Under
Tax Topics - General Concepts - Ownership
Crown deemed trust interest did not have the attributes of beneficial property ownership

The Crown challenged an order of the Alberta judge in CCAA proceedings regarding the Canada North group of companies that “priming charges”...

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Words and Phrases
beneficial ownership
trust

Magren Holdings Ltd. v. The Queen, 2021 TCC 42, aff'd on other grounds 2024 FCA 202 -- summary under Ownership

Full Title
Magren Holdings Ltd. v. The Queen, 2021 TCC 42, aff'd on other grounds 2024 FCA 202
Summary Under
Tax Topics - General Concepts - Ownership
acquisition of income fund units to be held for a few days before their redemption did not represent an acquisition of beneficial ownership

The appellants, were private companies controlled by a resident individual (Grenon), whose RRSP held 58% of the units of a publicly traded income...

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Words and Phrases
beneficial ownership

Singh v. The Queen, 2019 TCC 265 -- summary under Ownership

Full Title
Singh v. The Queen, 2019 TCC 265
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...

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Words and Phrases
beneficial ownership

Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62 -- summary under Ownership

Full Title
Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62
Summary Under
Tax Topics - General Concepts - Ownership
test of beneficial ownership

A limited partnership was found to have immediately transferred the beneficial ownership of applications to the Saskatchewan government for potash...

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Words and Phrases
beneficial ownership

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