In Grenon v. Canada (Fed CA, 2025) the Federal Court of Appeal considered the specific statutory interpretation of the term "hold":
[145] Before I examine other uses of "“hold”" in the Income Tax Act and Regulations, I acknowledge that "“hold”" has many possible meanings. However, I am satisfied that, in the context of the Income Tax Act, "“hold”" is intended to mean "“own”", unless the context in which it is used indicates otherwise. I see nothing in Regulation 4801 that suggests hold is not intended to mean own. To the contrary, as noted in paragraph 161 below, the prescribed conditions were once expressly described as concerning dispersal of ownership.
The author has waived all copyright and related or neighboring rights to this Isthatlegal.ca webpage.
