Search - "Contribution of Property"

In your scenario, the issue becomes whether the election by the spouse not to receive the income of the trust results in a contribution of property by the surviving spouse that increases the capital of the trust. ...

Principal Issues: tax consequences arising from a contribution of property to a joint venture by a venturer who reports income on the cash basis Position: no gain or loss is recognized at the time of contribution unless the joint venture is in fact a partnership Reasons: a joint venture is not recognized as a separate person for tax purposes CICA handbook recommends proportionate consolidation method, with adjustments to account for differences between cost to venturer and the value used for determining the increased interest. ...

Based on our limited understanding of the facts in the above-noted situation, although the cash used to fund Spouse A’s initial share investment in Opco and to make the loan to Opco was stated to be from cash that came from a joint account in the name of Spouse A and Spouse B, the legal form of these transactions strongly suggests that Spouse B has not made any direct or indirect contribution of property to Opco. ...