Subsection 74.1(1) - Transfers and loans to spouse or common-law partner
Cases
Lipson v. Canada, 2009 DTC 5528, 2009 SCC 1, [2009] 1 S.C.R. 3
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | policy of spousal attribution rule: cannot exploit spousal status on property transfers | 332 |
The Queen v. Kieboom, 92 DTC 6382 (FCA)
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Words and Phrases
transfer| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 58 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 67 |
Garant v. The Queen, [1985] 1 CTC 153 (FCTD)
Beique v. The Queen, 81 DTC 5050, [1981] CTC 75 (FCA)
Murphy v. The Queen, 80 DTC 6314, [1980] CTC 386 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | included right to be included in class of discretionary beneficiaries | 44 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 104 |
Lackie v. The Queen, 79 DTC 5309, [1979] CTC 389 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | 64 |
Administrative Policy
7 October 2016 APFF Roundtable Q. 19, 2016-0655841C6 F - Reimbursement of attributed income
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1) | no obligation to repay income reallocated to other partner | 158 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | excess disposition proceeds not required to be repaid | 85 |
29 June 2016 External T.I. 2016-0642811E5 - attribution rules - spouses
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S4-F3-C1 - Price Adjustment Clauses
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19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | subscription for discretionary shares of Opco might represent a s. 15(1) benefit conferred by Opco on subscriber, or engage s. 69(1)(b) where this is benefit conferred by existing shareholder | 203 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | Kieboom/s. 69(1)(b) rather than s. 15(1) where benefit conferred by shareholder rather than corporation | 185 |
19 April 1995 External T.I. 5-943123 -
26 September 1994 T.I. 941201 (C.T.O. "Attribution and Community Property")
31 May 1994 T.I. 941179 (C.T.O. "Inter-spouse Transfers and RRSPs")
93 C.R. - Q. 36
8 May 1991 T.I. (Tax Window, No. 3, p. 22, ¶1250)
4 May 1994 T.I. 940082 (C.T.O. "Attribution Rules")
14 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 12, ¶1091)
86 C.R. - Q.43
Articles
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Beneficiaries Resident in Canada", Chapter 4 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016.
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Subsection 74.1(2) - Transfers and loans to minors
Cases
Romkey v. Canada, 2000 DTC 6047 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 10 |
Sachs v. The Queen, 80 DTC 6291, [1980] CTC 358 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(14) | 83 |
See Also
Krauss v. The Queen, 2009 DTC 1394 [at 2155], 2009 TCC 597
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) | family trust allocated unreasonable return on its nominal-cost units | 200 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 47 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 47 |
Harvey v. The Queen, 98 DTC 1089 (TCC)
Romkey v. The Queen, 97 DTC 719 (TCC)
Administrative Policy
8 May 2001 External T.I. 2001-0072705 - Romkey - Estate Freeze
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