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Mr. Smith, who is 61 years of age, incorporated his company 20 years ago for $100 of share capital. He has worked full time for
Mr. Smith, who is 61 years of age, incorporated his company 20 years ago for $100 of share capital. He has worked full time for the business since then and has prospered. The company now has some excess capital. He has decided to have his wife set up an investment holding company and his company will lend her company $100,000 of cash for her to invest and thereby split income. Will the corporate attribution rules apply?
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