A resident husband and wife owning a number of corporations, each of which has its own business and full-time staff, work on a full-time basis for the various companies (whose shares are not excluded shares), but do not work for any particular company at least 20 hours a week. Would dividends above a reasonable amount be subject to the tax on split income (“TOSI”)?
CRA indicated that since neither spouse worked more than 20 hours in any business carried on by any of the particular corporations, the requirements of the bright line test for exclusion under s. 120.4(1.1)(a) was not met.