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Overview of income attribution rules

Developed for the In-Depth Tax Program, this course provides a comprehensive understanding of the attribution rules in the Income Tax Act. You will learn to identify when they apply, their implications and exceptions.

Are you a practitioner who would like a better understanding of when the income tax attribution rules apply? If so, this course is for you.

This course will help you learn to identify when the income attribution rules apply, and their implications and exceptions. Specifically, the course examines transfers of property between spouses, to minors, and non-arm’s length transfers to trusts or corporations made to benefit a spouse or minors, as well as indirect payments and corporate attribution.

This course highlights key concepts and critical tax compliance issues integrating elearning modules with knowledge checks and scenario activities designed for you to complete at your own pace and revisit when necessary.

This course is based upon enacted Canadian income tax legislation as of March 31, 2021.

explaining what attribution is and why it is important
applying the spousal attribution rules using fact scenarios, and describing how certain spousal loans can avoid attribution
applying the attribution rules on transfers to minors
explaining the attribution rules that apply where there is a transfer to a trust
identifying the tax implications of not transacting at fair market value between non-arm’s length parties
recognizing that attribution rules will be prevented from applying when using them for advantageous tax planning or when other rules take precedence (e.g., TOSI)
identifying the conditions and describing the tax implications of indirect payments, using fact scenarios
identifying whether the corporate attribution rules apply

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