Attribution Rules

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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In addition, the number of disputes and potential double taxation will likely increase due to different interpretations of what constitutes "negotiating material elements of contracts" or in the application of modified profit attribution rules that are still to be determined.
SJ: My suggestion for adding to or deleting from the Internal Revenue Code, outside of controversial political/policy matters, would be to have, if possible, as a technical matter, a uniform set of attribution rules to replace the many, different, complex attribution rules that are scattered throughout the Code.
Attribution rules apply to treat certain family members as owners for this purpose.
When determining whether an S corporation owner is a 2% shareholder, it's important to consider the family attribution rules.
These attribution rules also apply to any taxable capital gains or allowable capital losses generated by the transferred property.
Under Section 382, stock ownership would be determined under complex attribution rules pursuant to the Tax Code and generally includes shares held directly, indirectly (through intervening entities) and constructively (by certain related parties and certain unrelated parties acting as a group).
The Income Tax Act (the Act) contains various attribution rules that apply when an individual transfers property to his or her spouse (or common law partner).
Lobbied successfully to change the Federal Communication Commission's attribution rules requiring a cooperative to include a director's outside income in the company's revenues when applying for spectrum bidding credits.
If the stock redemption plan is selected for a family-owned corporation, the possible application of the attribution rules of Internal Revenue Code Section 318 must be considered.
The term accountable refers to attribution rules established in the first Strategic Arms Reduction Treaty--START I--signed by the U.
Disproportionate redemptions are further complicated by the application of the attribution rules of Section 318, which treat shareholders as owning the shares of certain family members and other entities as well as their own shares (Example 5).