Attribution Rules

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Attribution Rules

In Canada, a series of rules set by the Canada Revenue Agency governing transfers of assets between family members. For example, the attribution rules do not allow two spouses to divide income between themselves in such a way that it reduces their overall tax liability. Attribution rules were devised to prevent citizens from taking advantage of family relations to unfairly avoid taxes. See also: Tax evasion.
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5, the transfer would trigger the attribution rule of section 74.
The diversity order also intended to modify the equity-debt plus attribution rule and allow an interest holder to exceed the 33% ownership limit without triggering attribution.
At least when the attribution rule for trusts holding investment companies was enacted in the mid-1980s, the deferral rules that applied to trusts alone were only modestly restrictive, as discussed earlier.
7) If stock is deemed to be owned under another attribution rule, however, the ownership can be reattributed to another family member.
Halpern acknowledged Holmes' reading of the regulation for other types of custodial accounts, but wrote that because of an IRA'S special tax treatment, regarding it in such a fashion "utterly subverts the rationale for the attribution rule in the regulation.
318(a)(3)(C) attribution rule, and the issue of how to define a related person for purposes of the CFC look-through rule is not addressed.
whether the percentage under a particular attribution rule is "equal to" or "greater than.
318(a)(3)(C) attribution rule deems the corporation to own any stock owned by that shareholder.
Third, the House bill modified the attribution rule for purposes of determining whether an acquisition has occurred.
856(h)(1)(B) eliminates the PHC partnership attribution rule for the determination of REIT closely held status, but this attribution rule remains intact for purposes of Pile determinations, and there is no other provision that prevents the PHC rules from applying to REITs or their taxable REIT subsidiaries (TRSs).
Accordingly, this full stock attribution rule treats partnerships in a manner similar to members of the qualified group.
For example, the elimination of the temporary regulations' unwieldy earnings and profits attribution rule and the requirement that the section 367(b) notice simply be attached to the return (rather than filed separately with the IRS District Director) will ease compliance burdens for taxpayers and the government alike.