TOSI

Estate planning and TOSI – Part II

In my previous blog, Estate planning and TOSI Part I, I introduced the concept of the tax on split income (TOSI) continuity rules which are extremely important when estate planning.  The objective of the continuity rules is to afford the beneficiary, who would not have an excluded amount of their own, with an excluded amount exception TOSI. The continuity rules accommodate many estate situations, but the rules do not accommodate….

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Business Succession Planning, Estate Planning, Tax Issues

Estate planning and TOSI – Part I

Finance stated that the purpose of the revised tax on split income (TOSI) regime, which became effective January 1, 2018 was “to limit the ability of owners of private corporations to lower their personal income taxes by sprinkling their income to family members who do not really contribute to the business.”[1] The objectives related to estate planning generally have nothing to do with income splitting, but families with private companies need to consider TOSI….

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Business Succession Planning, Estate Planning, Tax Issues

The Senate Strikes Back?

The latest chapter in the ongoing saga of the federal government’s reforms to the taxation of private companies was released on December 13, 2017. On that date, the Minister of Finance released the draft legislation and explanatory notes for the revised version of the “income sprinkling” or “TOSI” (tax on split income) rules that were first released on July 18, 2017. The release also includes a guidance document that is….

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Tax Issues
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