- 主题发起人 唐人Jason
- 发布时间 2009-07-21
唐人能否给解答一下，
第一段是讲资本利得是可以转让给孩子的，让孩子去课税。
Transfers to other family members
A transfer of capital property to other family members is taxed just as if you sold the property at its FMV. If the property has been transferred to a child, grandchild, niece or nephew, you must continue to report any income earned on such property after it has been transferred—such as interest or dividend income—until the child reaches 18 years of age. After 18, attribution no longer applies and that individual must report the income. Capital gains, on the other hand, do not have to be attributed to you (regardless of the age of the child). This can be a useful income-splitting tool. However, make sure that any capital gain realized by a minor child is not subject to the “kiddie tax” rules (see topic 114).
但是这个又受到KIDDIE TAX的制约， KIDDIE TAX对资本利得是要按最高税率交税，那还不如直接就赠与人交了算了。
最后又说可以通过一定安排来绕过KIDDIE TAX，具体是怎么操作的呢？
topic 114
However, there are rules to prevent income splitting with minors—these are referred to as the “kiddie tax” rules. These rules assess tax at the top marginal rate on taxable dividends from a private corporation received by any child under the age of 18. It doesn’t matter if the dividends are received directly or through a trust or other structure. The tax will also apply to income from property such as certain rental and financing income that is allocated to minor children. Income from property inherited from the minor’s parent is excluded from this rule. The “kiddie tax” also applies to capital gains allocated to a minor child from the disposition of shares to a non-arm’s-length person, provided dividends received on those shares would have been subject to the tax.
There is certain planning that can be done to deal with these rules. You should contact your tax adviser to review your situation and determine the best planning strategy
第一段是讲资本利得是可以转让给孩子的，让孩子去课税。
Transfers to other family members
A transfer of capital property to other family members is taxed just as if you sold the property at its FMV. If the property has been transferred to a child, grandchild, niece or nephew, you must continue to report any income earned on such property after it has been transferred—such as interest or dividend income—until the child reaches 18 years of age. After 18, attribution no longer applies and that individual must report the income. Capital gains, on the other hand, do not have to be attributed to you (regardless of the age of the child). This can be a useful income-splitting tool. However, make sure that any capital gain realized by a minor child is not subject to the “kiddie tax” rules (see topic 114).
但是这个又受到KIDDIE TAX的制约， KIDDIE TAX对资本利得是要按最高税率交税，那还不如直接就赠与人交了算了。
最后又说可以通过一定安排来绕过KIDDIE TAX，具体是怎么操作的呢？
topic 114
However, there are rules to prevent income splitting with minors—these are referred to as the “kiddie tax” rules. These rules assess tax at the top marginal rate on taxable dividends from a private corporation received by any child under the age of 18. It doesn’t matter if the dividends are received directly or through a trust or other structure. The tax will also apply to income from property such as certain rental and financing income that is allocated to minor children. Income from property inherited from the minor’s parent is excluded from this rule. The “kiddie tax” also applies to capital gains allocated to a minor child from the disposition of shares to a non-arm’s-length person, provided dividends received on those shares would have been subject to the tax.
There is certain planning that can be done to deal with these rules. You should contact your tax adviser to review your situation and determine the best planning strategy
学习了好几遍，有些问题还是不那么清楚。请问唐人，前面提到家庭信托，信托人和受托人可以是同一人，如果我是这个信托人又是受托人，受益人是子女，这样的信托帐户的管理权完全就是我自己了，对不对？离岸信托即将终结，那在加拿大国内这个信托除了财产保护外，在税务上有什么有利的么？是延税还是别的什么？你前面提到的永久移民信托（奶奶信托）的税务有利还存在吗？
另外一个问题，国内的PE投资收益计税时按资本增值计还是别的类别？
刚登陆仨月，安顿停当，学习和筹划"资产规划”中，人民币资产的比重大让人心有隐忧，不在BC省，不能当面请教，望于此不吝赐教，谢谢！
另外一个问题，国内的PE投资收益计税时按资本增值计还是别的类别？
刚登陆仨月，安顿停当，学习和筹划"资产规划”中，人民币资产的比重大让人心有隐忧，不在BC省，不能当面请教，望于此不吝赐教，谢谢！
如果你是信托的受托人，那么信托所拥有的投资账户的实际控制人就是你。但是，如果你即使委托人，又是受托人，可能信托的资产保护作用就很弱了，同时节税作用也就比较弱了。
离岸信托并没有“终结”，即将被终结的委托人和受益人均为加拿大居民的离岸信托（即移民信托）的五年税务假期。但是，奶奶信托仍被视作永久的非居民纳税人。
关于PE投资“收益”，请问“收益”指的是由所投资的股权所获红利，还是由出售股权所获价差利润？
不客气。
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