Archive for the ‘Loans’ Category

ATTRIBUTION RULES AND PLANNING REVISITED

Tuesday, October 18th, 2016

Recently the Canada Revenue Agency (the “CRA”) issued a technical interpretation on the application of the income attribution rules under the Income Tax Act (“ITA”) which serves as a good primer particularly when a personal representative is looking at the deceased’s prior year returns with joint accounts and ...

ESTATE FREEZES AND CORPORATE ATTRIBUTION RULES: A QUICK REFRESHER

Tuesday, April 12th, 2016

When an individual taxpayer transfers or loans directly or indirectly property to a corporation, certain provisions of the Income tax Act (“the Act’) may deem the transferor to have received annual interest income on the property at the prescribed rate as set out in the Regulations of the Act. The ...