Attribution Rules

Attribution Rules is a comprehensive course designed to help accounting and tax professionals understand and apply one of the most important anti-income-splitting frameworks in Canadian tax law. Focusing on Sections 74.1 to 74.5 of the Income Tax Act, this course explains how income and capital gains can be attributed back to a transferor when property is transferred or loaned to a spouse, common-law partner, or minor child. Participants will explore how attribution applies to property income, capital gains, substituted property, and indirect transfers, as well as how these rules interact with family trusts and corporations. The course also examines key exceptions and relieving provisions, including fair market value transactions, prescribed rate loans, and rules affecting separated spouses and emigrants. Practical case studies illustrate common planning strategies, frequent missteps, and how the CRA evaluates compliance, including the role of the General Anti-Avoidance Rule (GAAR). Designed for professionals involved in personal tax, family tax planning, estate planning, and succession strategies, this course emphasizes practical application. Learners can expect clear explanations, real-world examples, and structured guidance that builds confidence in identifying attribution risks and structuring transactions appropriately. Delivered fully online and self paced, the course includes video instruction, downloadable reference materials, and practical review questions to reinforce understanding. It is suitable for accountants seeking to strengthen their expertise in family and estate-related tax planning while maintaining compliance with Canadian tax legislation. This course contributes toward the Canadian Tax Mastery Certificate, the Certificate in Personal and Family Taxation, and the Estate and Succession Planning Certificate, supporting ongoing professional development and continuing education in advanced Canadian tax practice.