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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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If the corporate attribution rules apply, you may have to pay tax each year on a certain amount of deemed interest income.
It has been a longstanding policy of the government to restrict the benefits of income splitting; as a consequence, there are provisions in the Income Tax Act (the Act) called attribution rules that are designed to limit income-splitting opportunities.
318 attribution rules (tested immediately after the acquisition of the target corporation's stock or, in the case of a series of transactions, immediately after the last transaction).
 
 
 
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