Course Schedule

Course Modules

Review and Practice

Exam Preparation

Resources

Module 10: Transfers of property among family members
Overview
The transfer of property between persons not dealing at arm’s length is one of the elements that must be considered in taxation to ensure that there are no unexpected tax consequences. The ITA contains rules to prevent tax benefits inconsistent with the spirit of the ITA when people are not dealing with each other at arm’s length. These rules apply mainly where the beneficiary of the transfer or loan of property does not give the transferor sufficient consideration or there is an unacceptable attempt to split income.
To reduce taxes on death, the situation can be planned by carrying out an estate freeze, which involves estimating the taxes payable on death and limiting them to this estimate. This module describes some different freezing techniques that are available.
Module 10 focuses on (1) your technical knowledge in taxation, and (2) your professionalism in respect to the integrative approach. The technical material mainly focuses on the tax treatment of gifts and non-arm’s length transactions, the attribution rules that limit the ability to split income within a family unit to take advantage of the progressive tax rates, and the usefulness of the estate freeze mechanism for reducing taxes on transferring wealth to the next generation. From an integrative perspective, professionalism includes relations with clients, their family, and the professionals with whom the CGA is required to work, as well as with CRA and any other government authority.
So that you can make sure that you have assimilated the planning and reorganization concepts seen throughout the course, the module closes with two comprehensive cases that require the application of the different rules you studied in TX2 . The module