3 December 2018 CPA Canada Roundtable, 2018-0773811C6 - Tax on Split Income (TOSI) -- summary under Subparagraph (a)(ii)

Example III: Income not from a related business (pp. 23-24)

B, aged 20, was issued 20% of the shares of Opco (a CCPC) as part of his compensation for programming work. Opco is majority-owned by an unrelated individual (A, aged 40). A dividend paid by Opco to B is not subject to TOSI given that it is not income from a related business because there is no “source individual” (A is not related to B).

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Income Tax Act - s. 120.4(1) - Related Business - (a)(ii)
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