4 July 1994 External T.I. 9411125 - ATTRIBUTION OF INTEREST ON JOINT ACCOUNTS

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues:

reporting of interest income on a joint account held by spouses

Position TAKEN:

question of fact as to the extent to which attribution will apply

Reasons FOR POSITION TAKEN:

insufficient facts to determine an appropriate split

A. Humenuk
XXXXXXXXXX		941112

July 4, 1994

Dear Sir:

Re: Reporting of Interest on Joint Accounts

We are replying to your letter of April 18, 1994 concerning the taxation of interest income held in your parents' joint account.

The confidentiality provisions of the Income Tax Act prohibit us from discussing the income tax affairs of any taxpayer without the written consent of that taxpayer. Although we are unable to comment on any tax matters which might relate specifically to either of your parents, we offer the following general comments concerning joint holdings of property.

As stated on page 14 of the 1993 General Tax Guide, an individual is required to report his or her share of interest earned on a joint account based on the amount he or she contributed to the account. Where the other account holders include a spouse or minor child of the individual, the individual's contribution to the account will include any amount loaned or gifted to that account holder as well as the amount the individual contributed to the account. The attached Interpretation Bulletin IT-511R "Interspousal and Certain Other Transfers and Loans of Property" provides additional details concerning the attribution of income to a spouse.

If your father determines that an adjustment is required to his income tax return for a taxation year after 1984, he should send a letter, detailing the amount of the adjustment requested, his social insurance number and the year or years involved to the taxation centre.

We trust our comments will be of assistance to you.

Yours truly,
J.A. Szeszycki
for Director
Business and General Division
Rulings Directorate
Legislative and Intergovernmental
Affairs Branch