First published by the Canadian Tax Foundation in 2019 Ontario Tax Conference and Live Webcast (Toronto: Canadian Tax Foundation, 2019).
Using practical examples, this paper provides an update on Tax on Split Income (TOSI), taking account of recent CRA interpretations. It also discusses the characterization of income and activity as it is relevant to TOSI, such as whether income is business income or income from the provision of services. Lastly, the authors make suggestions on best practices for keeping documentary evidence when relying on selected excluded amount exceptions.
