Returning Canadian resident income attribution

This is our main tax information forum which deals with topics concerning Canadians living and working in the U.S., U.S. citizens contemplating working in Canada, and all aspects of Canadian and U.S. income tax and related adminstrative issues.

Moderator: Mark T Serbinski CA CPA

Post Reply
goldstone
Posts: 32
Joined: Wed May 29, 2019 11:27 am

Returning Canadian resident income attribution

Post by goldstone »

If a couple are tax resident in Canada and one spouse gifts funds to the other then any income earned by the gifted funds is attributed back to the transferor for taxation. However, if the transferor becomes non Canadian resident then the attribution ceases.

Would anyone know......If a Canadian couple have been non Canadian resident for several years, and in the non resident period one spouse gifts funds to the other spouse.......When they return to Canada would the attribution rules apply such that any income earned from the gifted funds is attributed back to the transferor ?

Thanks very much for any advice.
Post Reply