# Attribution on money from non-resident
**URL:** https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255
**Category:** Tax Topics
**Created:** [September 2, 2025, 5:03pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255 "2025-09-02T17:03:03Z")
**Posts on this page:** 6
**Page:** 1
### Author:  [@dongminkun](https://www.protaxcommunity.com/u/dongminkun)
#### Post date: [September 2, 2025, 5:03pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255/1 "2025-09-02T17:03:03Z")
I read that attribution rule doesn’t apply once a transferor becomes a NR. So I assume if a resident borrows money from NR related persons (NR spouse or NR parent), the attribution rule doesn’t apply and no interest payment is needed. Am I correct?
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### Author:  [@RRAccounting](https://www.protaxcommunity.com/u/RRAccounting)
#### Post date: [March 20, 2026, 6:51pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255/3 "2026-03-20T18:51:23Z")
Well, you are going to run into a very funny situation there, does the debt become a foreign property now? Because it’s going to be debt owe to forein person.
If the interest in (b)(ii) is not paid within the described time then the indebtedness will not meet the requirements for exemption from the attribution rules under subsection 74.5(1) in the particular year or in any later year.
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### Author:  [@RRAccounting](https://www.protaxcommunity.com/u/RRAccounting)
#### Post date: [March 29, 2026, 9:51pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255/5 "2026-03-29T21:51:06Z")
Just like a lot of the interpretation, it all depends on facts, but there is exception to the attribution rule, so, there is something in place. This is where I think “intent’ still a great consideration, if you are not intent to split the income, just do a legal transfer or gift, then you won’t have that concern. If you are concerned of losing something, then the main purpose is to split the potential income, you are just trying to find way to avoid the taxes.
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### Author:  [@RichardSpar](https://www.protaxcommunity.com/u/RichardSpar)
#### Post date: [March 31, 2026, 8:36pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255/8 "2026-03-31T20:36:36Z")
Your understanding is correct. By virtue of 74.2(3) the spousal attribution rule under 74.2(1) does not apply to your deemed disposition upon emigration from Canada unless you and your wife jointly elect to have 74.2(1) apply when you file your income tax returns for the year you emigrate from Canada.
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### Author:  [@RRAccounting](https://www.protaxcommunity.com/u/RRAccounting)
#### Post date: [March 31, 2026, 9:39pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255/9 "2026-03-31T21:39:53Z")
My comment was purely for discussion purposes only, not based on any actual information.
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### Author:  [@abechew309](https://www.protaxcommunity.com/u/abechew309)
#### Post date: [April 1, 2026, 6:31pm UTC](https://www.protaxcommunity.com/t/attribution-on-money-from-non-resident/11255/13 "2026-04-01T18:31:43Z")
Here you state:
”(I am the only title owner of that account and have not made my wife beneficiary owner nor nominee in that account)”
But in your other thread on the same topic, you state:
”purchase happened (using my wife’s money)”
Since this appears to be somewhat contradictory (manipulative?) regarding the facts as to beneficial ownership, it seems to me that this topic does not really lend itself well to being properly “solved” here.