Corporate attribution tips

The authors summarize some methods for avoiding or mitigating corporate attribution:

The corporate attribution rules do not apply where the transferee is a small business corporation.
The transferor could consider effecting a freeze using a stock dividend. (But will the CRA apply GAAR?)
The rules do not apply where the designated person’s shares are held in a trust described by subsection 74.4(4).
A corporation could transfer property (that was not received from an individual) to another corporation that will be frozen.
The freeze corporation can repay loans or redeem shares that generate the deemed interest.
The freezor can receive interest or dividends as part of his or her ‘compensation’, which would reduce or eliminate the deemed interest.

Player, Katlai and Neilson “Corporate Attribution: Avoid It or Apply Mitigation Strategies” 12:2 Canadian Tax Focus (May 2022)

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