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Attribution Rules |
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Attribution Rules A set of rules created by Canada Customs and Revenue Agency (CCRA) that prevents investors from transferring assets between family members with the intention of avoiding taxes. Notes: The goal of these rules is to prevent individuals in higher tax brackets from transferring assets to family members who are taxed at lower marginal rates in an attempt to evade being taxed at their own high rate. These rules were implemented to close a loophole in the Canadian tax system. |
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| Thus, if 10 individuals each own 10% of a partnership, which in turn owns 50% of the loss corporation being analyzed, the attribution rules will treat each individual as a 5% owner (and shareholder) of the loss corporation for Sec. Recently the Tax Court, in a case of first impression, had to decide how the family attribution rules applied in a section 382 context. Use of option and community property attribution rules. |
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Attribution Rules
