7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6 - TOSI & Meaning of Excluded Business -- summary under Excluded Business

The spouse of a professional works over 20 hours per week as a part-time receptionist in the professional practice of his corporation (XCo). She does not receive a “market” salary for her services of $18,000, and instead receives an annual dividend of $150,000 on her non-voting preferred shares of XCo.

CRA indicated since she satisfies the 20 hours per week test in s. 120.4(1.1)(a), her dividend income would be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income.

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