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- Title
CORPORATE ATTRIBUTION: THE "ANTI-FREEZE" RULE.
- Authors
Festeryga, Paul W.
- Abstract
The corporate attribution rule (CAR) can present a significant challenge to practitioners in planning and implementing estate freezes. While CAR is relevant to all transfers or loans to corporations, this article focuses on the application of CAR to some common estate-freeze scenarios and discusses various planning options. These scenarios include "drop-down" freezes and stock dividend freezes. Particular attention is paid to the Canada Revenue Agency's interpretations relating to CAR with a view to providing insight as to potential assessing practices.
- Subjects
CANADA; ESTATE freezing; ESTATE distributions; ESTATE planning; CANADA Revenue Agency
- Publication
Canadian Tax Journal / Revue Fiscale Canadienne, 2010, Vol 58, Issue 3, p675
- ISSN
0008-5111
- Publication type
Article