This module examines the tax treatment of property transfers between individuals who do not deal at arm’s length—most notably between spouses, former spouses, children, and other related parties. The focus is on attribution rules under Sections 74.1 to 74.5, as well as the legal distinction between legal ownership and beneficial ownership. Through practical examples, learners will understand h...
This module examines the tax treatment of property transfers between individuals who do not deal at arm’s length—most notably between spouses, former spouses, children, and other related parties. The focus is on attribution rules under Sections 74.1 to 74.5, as well as the legal distinction between legal ownership and beneficial ownership. Through practical examples, learners will understand how to identify non-arm’s length relationships, how income and capital gains can be inadvertently attributed back to the transferor, and how divorce, death, or trust structures may alter attribution outcomes.
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