Dates and location
Pricing
Hours
Dates and location
Pricing
Hours
Description
Participants will examine income‑splitting opportunities and restrictions in the Canadian Income Tax Act, with a practical focus on how the expanded Tax on Split Income (TOSI) regime affects families, private corporations, and common planning structures. Participants will analyze traditional prohibitions, rules that expressly allow splitting, and remaining strategies through examples and case studies.
Topics include:
- Introduction to income‑splitting concepts and planning context.
- Non‑TOSI restrictions: attribution rules (e.g., ss. 74.1–74.5, 56(2), 56(4.1), 75(2)), corporate attribution, and reasonableness (s. 67).
- Permissive rules/structures: CPP sharing and pension splitting, spousal RRSPs, RESPs, RDSPs, TFSA funding, fair‑market‑value transfers, and loans for value.
- Expanded TOSI framework: exclusions for minors and adults (including age‑based tests, excluded business, excluded shares, reasonable return), and scenario‑based application (fundamentals and advanced).
- Strategy toolkit: traditional methods that still work (e.g., prescribed‑rate loans, gifts to adult children, LCGE multiplication, salaries/director fees) and updated approaches under TOSI.
NOTE: This course description has been revised and reflects updates for 2026. If you have any questions, please contact pdevents@cpaontario.ca.
The CPA Ontario Tax Immersion Program
Schedule
- September 22, 2026, 8:30 a.m. - 12:30 p.m.
- September 23, 2026, 8:30 a.m. - 12:30 p.m.
Key Takeaways
By the end of this course, participants should be able to:
- Apply traditional Income Tax Act provisions that allow or restrict income splitting.
- Assess the application of the expanded TOSI rules to a range of fact patterns.
- Identify legacy techniques that no longer work and recognize viable current strategies.
- Advise on practical income‑splitting approaches and related documentation.
Who Will Benefit
CPAs with solid income tax fundamentals who advise individuals, professionals, or business owners on income‑splitting matters.
Prerequisite(s)
- General personal and corporate income tax knowledge.
- Prior exposure to income‑splitting or owner‑manager remuneration planning (recommended).
Speaker(s)
Kris Himberg-Larsen is a partner at Wilkinson and Company LLP, received his CA in 2003 and completed the In-Depth Tax Course in 2006. Kris handles complex tax issues involving corporate reorganizations, and tax and succession planning. He mentors staff in house and has been an instructor for the CPAO for ongoing PD courses and at the School of Accountancy.
How to Access the Course
This course is delivered as a live webinar. To receive verifiable CPD hours, you must attend the session live. We recommend joining at least 5 minutes before the scheduled start time. For the best interactive experience, please use a computer equipped with a camera and microphone.
A reminder email with the Zoom link and course details will be sent two business days before the session. If you do not receive it, please check your spam or junk folder.
The same information, including any available materials, will also be posted in advance on our Blackboard LMS.
Registration, cancellation, withdrawal and all other CPA Ontario PD policies can be found here.