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

A limited partnership was found to have immediately transferred the beneficial ownership of applications to the Saskatchewan government for potash exploitation rights (the “Purchased Applications and Purchased Permits”) to a corporation (“Devonian”) immediately upon entering into a sale agreement of the Purchased Applications and Purchased Permits with Devonian. In this regard, D’Arcy J referred (at para. 95) with approval to the finding in Prévost Car, 2008 TCC 231 (aff'd 2009 FCA 57) that “the beneficial owner is the true owner who enjoys and assumes all the attributes of ownership, without having to be accountable to anyone, including to the legal owner, as to how the property is used or dealt with.”