Canada v. Rose, 2009 DTC 5076 [at at 5806], 2009 FCA 93 -- summary under Subsection 160(1)

The taxpayer's husband transferred his co-ownership interest in the matrimonial home to the taxpayer in order to prevent a creditor from placing a lien on the home. In reversing the finding of the Trial Judge that her husband had only transferred registered title and not the beneficial interest to the taxpayer, Evans, J.A. stated (para. 31) that it was an "almost inescapable inference" from the statement of the husband's purpose in transferring title that "he intended to do this in the most effective, and lawful, manner" that is, by transferring his entire interest in the house" (para. 31).