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 the potential…
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…
My most recent blogs have explored the possible use of life insurance to completely eliminate the capital gain on death (assuming that sufficient insurance was in place) provided certain stop-loss rules do not apply. Not all was lost because, “grandfathered” agreements could prevent the application of the stop-loss rules.
There are lessons for everyone in the way the rich focus on long-term financial planning and wealth transfer.
The Canada Revenue Agency has announced the 2010 third quarter prescribed interest rate used to calculate taxable benefits for employees and shareholders for interest-free and low interest loans would be 1%. With this the lowest historical prescribed rate ever, it is an opportune time for taxpayers to reduce the tax bite through an income-splitting structure using loans.
