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 the impact of the TOSI rules through practical examples and CRA commentary.
Topics include:
- Introduction to income‑splitting concepts and planning context.
- Non‑TOSI restrictions: common attribution rules (e.g., ss. 74.1–74.3, 56(4.1)), and reasonableness (s. 67).
- Permissive rules/structures: CPP sharing and pension splitting, spousal RRSPs, RESPs, RDSPs, TFSAs, fair‑market‑value transfers, and loans for value.
- Expanded TOSI framework: impact of new rules on business owners and their families, exclusions for minors and adults (including age‑based tests, excluded business, excluded shares, reasonable return).
- Application of TOSI to various scenarios (basic and advanced).
- Strategy toolkit: traditional income splitting methods that still work and new requirements in light of TOSI.
NOTE: This course description has been revised and reflects updates for 2026. If you have any questions, please contact pdevents@cpaontario.ca.
Key Takeaways
By the end of this course, participants should be able to:
- Apply traditional Income Tax Act provisions that restrict or explicitly allow income splitting.
- Understand the expanded TOSI rules and apply them 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)
- Prior exposure to income‑splitting or owner‑manager remuneration planning (recommended).
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.
Speaker(s)
Milan Legris, LL.B., LL.M, TEP, is a tax and estate planning lawyer in Ancaster, ON. Milan restricts his work to consulting with other professional advisors for high-net worth individuals, senior executives and key employees, as well as owner-managers and their families. Milan was called to the Ontario bar in 1986 and is also an advisor and author of reference materials on taxation for the Law Society of Ontario’s (LSO) Professional Development and Competence Department. Milan was a lecturer and instructor for the LSO’s Bar Admission Course on taxation.