Calce Holdings Ltd. v. The Queen, 2005 DTC 959, 2005 TCC 335 -- summary under Agency

The taxpayer unsuccessfully contended that there was a secret verbal contract between it and a related individual to whom it sold shares that he would hold such shares as nominee for it, so that a gain on a subsequent sale of those shares was realized by it rather than him. The fact that he received and included in his taxable income a dividend paid on the shares immediately before the sale to the third parties, and a representation contained in the notice of objection of the taxpayer, were inconsistent with this contention.