7 June 2019 STEP Roundtable Q. 3, 2019-0799901C6 - TOSI and Hours Worked -- summary under Paragraph 120.4(1.1)(a)

A business is carried on through a corporation owned by husband and wife, who each contribute 5 hours per week of time to the business. This did not exceed the 20 hours per week safe harbour in s. 120.4(1.1)(a). CRA noted that this was similar to Example 9 of CRA’s split-income guidelines, and stated that they both could be considered to be actively engaged in the business – but indicated that this was a question of fact.