Section 74.4

Subsection 74.4(2) - Transfers and loans to corporations

Administrative Policy

11 October 2019 APFF Roundtable Q. 16, 2019-0812751C6 F - 74.4(2) and 120.4 interaction

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Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) - Paragraph 74.4(2)(g) only s. 74.4(2)(g) provides relief from the joint application of the TOSI and s. 74.4(2) rules 252

6 October 2017 APFF Roundtable Q. 9, 2017-0709071C6 F - Corporate Attribution Rules

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Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(5) unborn children and spouse not designated persons re freezer trust 231

May 2016 Alberta CPA Roundtable, Income Tax Q.9

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Words and Phrases
one of the main purposes

8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules

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11 December 2015 External T.I. 2015-0601561E5 F - Attribution Rules

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2 June 2015 External T.I. 2015-0570071E5 F - Attribution Rules Trust

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10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) not engaged if stock dividend is proportional 211
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SI apportionment to stock dividend prefs 251
Tax Topics - Income Tax Regulations - Regulation 6205 - Subsection 6205(2) purpose test in Reg. 6205(2)(a) is not necessarily accomplished by all estate freezes/"arrangement" broad 413

19 September 2011 External T.I. 2011-0410411E5 F - Attribution - Transfers to Corporations

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1 April 2003 External T.I. 2003-0004125 F - Freeze by Paying a Stock Dividend

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1 March 2001 External T.I. 2001-0067725 - 74.4 and estate freezes

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28 January 1997 External T.I. 9635055 - attribution under 74.4(2) if 74.1(1) and 74.2(1) apply

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20 March 1995 External T.I. 9429925 - 74.4(2) AND AMALGAMATION

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12 October 1994 External T.I. 9411485 - SECTION 74.4 - SMALL BUSINESS CORPORATION

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11 May 1994 External T.I. 9130715 - TRANSFER OF PROPERTY RE 74.4(2) AMALGAMATION

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17 February 1994 External T.I. 9401115 - ATTRIBUTION CONTROL CO INVEST IN PREF SHARE OF 2ND CO

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26 January 1994 External T.I. 9329955 - SUBSECTIONS 74.4(2) AND 74.5(7)

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30 March 1993 T.I. (Tax Window, No. 29, p. 23, ¶2454)

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92 C.R. - Q.34

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21 August 1992 T.I. (Tax Window, No. 23, p. 24, ¶2154)

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27 June 1991 Memorandum (Tax Window, No. 4, p. 13, ¶1320)

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11 June 1991 T.I. (Tax Window, No. 4, p. 29, ¶1298)

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2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1080)

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30 January 1990 Memorandum (June 1990 Access Letter, ¶1263)

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ATR-36 (4 Nov. 88)

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86 C.R. - Q.42

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Articles

Emes, "Planning for Immigration to Canada from Countries other than the United States", 1993 Corporate Management Tax Conference Report, c. 13.

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(4.1) 4

Paragraph 74.4(2)(g)

Administrative Policy

11 October 2019 APFF Roundtable Q. 16, 2019-0812751C6 F - 74.4(2) and 120.4 interaction

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Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) main purpose test can still apply even where designated persons are subject to TOSI 295

Subsection 74.4(3)

Articles

Alexander Demner, Nicholas McIsaac, "Freezes and Refreezes: Opportunities and Risks in the Era of Self-Isolation", COVID-19 and Canadian Tax for the Owner-Manager/Canadian Tax Focus (Canadian Tax Foundation), July 2020, p. 5

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Subsection 74.4(4) - Benefit not granted to a designated person

Administrative Policy

2016 Ruling 2014-0552321R3 F - Trust to trust Transfer

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (f) para. (f) exception applied on transfer from old discretionary inter vivos family trust to new trust with terms considered to be substantively the same 782
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Trust - Paragraph (g) trust holding property on its 21st anniversary for minors was not subject to s. 104(4) as their shares would have been deemed under the Trust Deed to be irrevocably determined by then 413
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(5.8) 104(5.8) applied to transfer to new trust with the same beneficiaries and essentially the same terms 51

7 November 2014 External T.I. 2014-0549571E5 F - Attribution rule

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8 February 1993 T.I. (Tax Window, No. 29, p. 7, ¶2422)

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Articles

Manu Kakkar, Alex Ghani, Boris Volfovsky, "Corporate Attribution: Refreeze May Cause Unsolvable Corporate Attribution Problem", Tax for the Owner-Manager, Vol. 18, No. 3, July 2018, p.6

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