Section 74.5

Subsection 74.5(1) - Transfers for fair market consideration

Administrative Policy

29 April 1994 T.I. 933662 (C.T.O. "Attribution Rules")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(2) 105

15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt 36

Articles

Summerville, "Income Splitting may be Implemented by Transferring Residential Property to Spouse", Taxation of Executive Compensation and Retirement, December 1989/January 1990

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Subsection 74.5(2) - Loans for value

Administrative Policy

10 June 2013 STEP Canada Roundtable, 2013-0480271C6 - Prescribed Rate Loan - 2013 STEP Roundtable Q 2

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29 April 1994 T.I. 933662 (C.T.O. "Attribution Rules")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(1) 105

21 October 1991 T.I. (Tax Window, No. 12, p. 20, ¶1544)

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19 July 1989 T.I. (Dec. 89 Access Letter, ¶1047)

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79 C.R. - Q.5

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Subsection 74.5(3) - Spouses or common-law partners living apart

Administrative Policy

88 C.R. - Q.54

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Subsection 74.5(5)

Administrative Policy

6 October 2017 APFF Roundtable, Q.9

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) a second freeze transaction by a family trust could be viewed as an indirect transfer by the original freezor 373

Subsection 74.5(7) - Guarantees

Administrative Policy

86 C.R. - Q.44

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Subsection 74.5(11) - Artificial transactions

Cases

Swirsky v. The Queen, 2013 TCC 73, 2013 DTC 1078 [at 431], aff'd 2014 FCA 36

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See Also

Mady v. The Queen, 2017 TCC 112

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Words and Phrases
one of the main purposes
Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership wife and children did not acquire beneficial interest in shares the taxpayer was to transfer to them, under tax plan, until the share transfer occurred 253
Tax Topics - Income Tax Act - Section 86 - Subsection 86(2) family members did not acquire beneficial interest in new shares until after completion of s. 86 reorg 285
Tax Topics - General Concepts - Fair Market Value - Shares arm’s length sales price established FMV for closing-date internal transfer of same shares 470
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) - Subparagraph 69(1)(b)(i) contemporaneous arm’s length sale price established that shares previously transferred at undervalue 468
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) was not responsible under s. 163(2) for the unbeknownst sharp practice of his tax advisor 658
Tax Topics - General Concepts - Price Adjustment Clause no jurisdiction to comment on application of price adjustment clause where the affected taxpayers are not appellants 223

Administrative Policy

24 March 2014 External T.I. 2014-0519661E5 - Subsection 74.5(11) Attribution

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