Basics & Definition
You are considered non-arm’s length with this group of people: parents, children, siblings, and spouse.
Who are related individuals?
Under ITA 69, the seller’s proceeds of disposition is deemed to be this.
Higher of FMV or actual proceeds?
Under ITA 73, transfers between these parties can occur at ACB.
Spouses or Common Law
Attribution rules “attribute” income back to which person?
Who is the transferor (original owner)?
In 2023, this pink-themed movie broke box office records and inspired a million memes.
What is Barbie?
A father sells an asset to his son at less than FMV to shift income — this is an example of what?
What is income manipulation through non-arm’s length transfer?
Under ITA 69, the buyer’s adjusted cost base (ACB) is deemed to be this.
Lower of FMV or actual proceeds?
If John sells shares to his spouse at ACB, what is his capital gain?
$0
Attribution applies to this type of income but not to this other type.
What is property/capital income but not business income?
“It’s giving ✨vibes✨” is Gen Z slang meaning this.
What is ‘it reminds me of / gives the energy or aesthetic of something’?
True or False: You are related to your adult nephew (over 18).
False
When the ACB of the buyer is different from the FMV of the seller, what are the resulting tax consequences?
What is double taxation?
Mary transfers Apple shares to her husband for ACB — what section allows this?
What is ITA 73 (spousal rollover)?
Attribution can apply to transfers between spouses and which other group?
What are related minors?
“ICYMI” stands for
‘In Case You Missed It’?
Name one reason the CRA created rules for non-arm’s length transfers.
To prevent income shifting and unfair tax reduction?
In John’s example, if FMV = $350K but he sells to his brother for $200K, what is John’s P of D?
$350,000?
Transferring assets to a lower-income spouse to reduce tax burden is referred to as?
Income splitting?
Name one way to avoid attribution under ITA 73.
→ What is electing out of section 73 and transacting at FMV with interest-bearing note?
The Jays won their back-to-back World Series championships in these two years.
1992 and 1993?
This ensures that income or capital gains from property transferred to a spouse or related minor are taxed in the hands of the original transferor, not the recipient.
What is income attribution?
In John’s example, if FMV = $350K but he sells to his brother for $200K, what is his brother's ACB?
$200,000
Name one outcome of using the spousal rollover incorrectly.
Income attribution back to the original owner
In a proper FMV sale to a spouse, what three things must occur to avoid attribution?
→ What are: sell at FMV, take back cash or promissory note, and charge interest.
This summer event fills the streets of Montreal with laughter and comedians from around the world
What is the Just for Laughs Festival?