Peragine v. The Queen, 2012 DTC 1287 [at at 3887], 2012 TCC 348 -- summary under Subsection 104(1)

Webb J. found that the taxpayer held a real property as an agent (and hence as a bare trustee) of his brother. The evidence consistently showed that the property was acquired for, and used in, the taxpayer's brother's business, and that mortgage payments came from the brother's business income. Although the proceeds of disposition of the property were disbursed to the taxpayer, the taxpayer only transferred the funds to his brother or to third parties at his brother's direction and for his brother's benefit.