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Income Splitting & Anti-Avoidance

Corporate Attribution Rule (Section 74.4) Calculator

Lend or transfer property to a corporation your spouse or minor child holds shares in, and the CRA assumes a minimum return back to you, whether the corporation actually pays it or not.

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How To Use This Calculator

Enter the amount transferred or loaned, and whatever interest or dividends you've actually received on it.

Section 74.4 deems you to have earned interest at the prescribed rate on the transferred amount every year, reduced by whatever you actually collected. The gap, if any, gets added to your income regardless of what the corporation itself decided to pay out.

Your Inputs

This applies specifically where a "designated person," a spouse, common-law partner, or a related minor, holds shares in the corporation the property was transferred to. Transfers to a corporation with no such designated person as shareholder are not caught by this rule.

Deemed Interest Benefit

-

Added To Your Income This Year

$0

Required Return At Prescribed Rate

$0

Actually Received (Interest + Dividends)

$0

Required Return vs. What You Actually Collected

-

-

This models the core deemed interest mechanic only. Related rules also attribute capital gains on the transferred property back to the transferor in many cases, and certain small business corporation exceptions can remove the transfer from this rule entirely, not modeled here.

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