Search results with tag "Attribution rules"
Additional Guidance on the Attribution of Profits to ...
www.oecd.orgAs to the profit attribution rules, the Report concluded that the changes to the definition of PE in Article 5 of the OECD Model Tax Convention did not require substantive modifications to the existing rules and guidance on attribution of profits to PEs under Article 7 of the OECD Model Tax Convention. However, the Report did mandate the
Income Splitting Strategies - CIBC
www.cibc.comThe “attribution rules” in the . Income Tax Act. make this difficult by generally attributing any income and, in some cases, capital gains (losses) earned (realized) on money transferred or gifted to a family member back to the original transferor; however, there are exceptions to the attribution rules that permit income splitting in a
All in the family: Attribution rules - Kravitz, Inc.
www.kravitzinc.comthe case of a spouse, attribution continues until the individuals are either formally divorced or legally separated under relevant state law. What is the impact of attribution?
FBAR: “Family Ownership” Attribution Rules (IRC §318)
www.gswlaw.com2. The “ownership” attribution rules of Title 26 (IRC §318) are not applicable to a FBAR (filing) (which includes a discretionary class of beneficiaries [i.e., family trusts]).