Tax on Split Income (TOSI)

This specialized module focuses on the Tax on Split Income (TOSI) regime and its profound impact on income splitting arrangements among family members. Learners will trace the evolution of the TOSI rules, including their expansion in 2018, and understand the categories of affected individuals (specified individuals, source individuals). The course unpacks key exclusions and safe harbours, such as excluded business and excluded shares tests, as well as the reasonableness criteria. Practical scenarios illustrate how TOSI applies to dividends, capital gains, and partnership income, and how taxpayers can structure affairs to comply with or avoid triggering TOSI.