Canadian attribution of income on gifted funds

[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.

[nelsona]

Please ask this on the tax forum. We've had a post or 2 in the past on this.