14 November 1989 Ministerial Correspondence 58904 F - Attribution Rules

By services, 18 January, 2022
Official title
Attribution Rules
Language
French
CRA tags
56(4.1)
Document number
Citation name
58904
Severed letter type
Ministerial Correspondence
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630487
Extra import data
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Main text
19(1) File No. 5-8904
  D.S. Delorey
  (613) 957-3495

November 14, 1989

Dear Madam:

This is in reply to your letter of October 13, 1989 concerning the attribution rule in subsection 56(4.1) of the Income Tax Act.

Where an individual has loaned property and the circumstances are such that the provisions of subsection 56(4.1) apply to attribute income from the property to the individual, it is our view that the attribution does not apply to such income that relates to a period following the death of the individual.

The above comments reflect an expression of opinion only and as such, they are not binding on the Department.  We trust however that they will be of assistance.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate