the tosi rules - ctf pp 2018/tosi.pdf · 5 the tosi rules –what’s new? tosi –application •...

The TOSI Rules –

What’s new?

Règles relatives au

fractionnement du

revenu – Quoi de neuf?

Katherine Borsellino, LL.B, J.D., LL.M (Fisc.)

Emilie Champagne-Couillard, LL.B, D.E.S.S. (Fisc.)

Richter LLP

Montreal

November 16, 2018

2

The TOSI Rules – What’s new?

Tax on Split Income (Kiddie Tax) – Pre 2018

• Purpose

− Limit and/or eliminate income splitting with minor children

• Application

− Canadian resident individual under the age of 18 (“Specified individual”)

− Earning certain forms of income from a private corporation, partnership or trust

(“Split income”)

− Exception for certain “Excluded amounts”

• Consequence

− Income is subject to the highest individual tax rate

− Certain personal tax credits are denied

3


Tax on Split Income (TOSI) – As of 2018

• Purpose

− Limit and/or eliminate income splitting with minors

− Limit and/or eliminate income splitting with adults

• Definitions

MODIFIED / EXPANDED DEFINITIONS

MODIFIÉES / ÉTENDUES

NEW / NOUVELLES

DEFINITIONS

• Excluded amount / Montant exclu

• Specified individual / Particulier déterminé

• Split income / Revenu fractionné

• Arm’s length capital / Capital indépendant

• Excluded business / Entreprise exclue

• Excluded shares / Actions exclues

• Reasonable return / Rendement

raisonnable

• Related business / Entreprise liée

• Safe harbor capital return / Rendement

exonéré

• Source individual / Particulier source

4


TOSI – Application

• Specified individual/ Particulier déterminé

− Individual (other than a trust) who is a resident in Canada (at the end of the year

or immediately before their death); or

− Minor who has a parent resident in Canada at any time of the year

• Split income / Revenu fractionné

− Dividend income (or shareholder benefit) derived from a [private] corporation

− Capital gains derived from the disposition of shares of a [private] corporation, an

interest in a partnership or trust or a debt obligation

− Certain partnership income and capital gains derived from a related business or

the rental of property (where a related person is actively engaged on a regular

basis in the activities related to the rental of property)

− Certain trust income and capital gains derived from a related business or the

rental of property (where a related person is actively engaged on a regular basis

in the activities related to the rental of property)

− Certain interest income derived from a [private] corporation, partnership or trust

5



• Related business / Entreprise liée

− Business carried on by a source individual

− Business carried on by a partnership, corporation or trust if a source individual is

actively engaged on a regular basis in the activities of the partnership

corporation or trust

− Business of a partnership if the source individual has an interest in the

partnership (directly or indirectly) at any time during the year

− Business of a corporation if a source individual owns shares or property

representing 10% or more of the FMV of the shares of the corporation

6



• Source individual / Particulier source

− Individual (other than a trust) who is a resident in Canada and is related to the

specified individual

• Related – para. 251(2)a)

• Deemed not related if living separate and apart because of marriage or

common-law relationship breakdown – para. 120.4(1.1)(e)

• Consequence

− Income is subject to the highest individual tax rate – 120.4(2)

− Certain personal tax credits are denied

7


TOSI

• Exceptions

− Income, capital gain or profit to the extent that such amounts qualify as an

excluded amount

− Inheritance

− Source individual who is 65 +

8


ExampleSettlor: 3rd party

Trustees: Founder

3rd party non-settlor, non-beneficiary

Beneficiaries:

• Founder (source individual and specified individual)

• Spouse (specified individual)

• Child 1 (25 +) - full time (source individual and

specified individual)

• Child 2 (18-24) - part time (specified individual)

• Child 3 (minor) (specified individual)

• Corporations controlled by Founder

9


During Operations – Employment Income

• TOSI does not apply to employment income

• General limitations when computing income will apply

− Income producing purpose (para. 18(1)(a))

− Non-capital expense (para. 18(1)(b))

− Reasonable (section 67)

− Shareholder benefit (section 15)

10


During Operations – Dividend Income

Excluded Amount – Non-Related Business / Entreprise non liée

(120.4(1)(e)(i))

SPECIFIED INDIVIDUAL CONDITIONS OF APPLICATION

X Founder

X Spouse

X Child 1 (adult, 25+)

X Child 2 (adult, 18-24)

X Child 3 (minor)

> 17 years old

x Not derived, directly or indirectly, from a related

business for the year

• Business carried on by a source individual (or)

Business carried on by a corporation where a source

individual is actively engaged on a regular basis

• Business of a corporation if a source individual owns

shares or property representing 10% or more of the

FMV of the shares of the corporation

11



Excluded Amount – Excluded Business [for the year] / Entreprise

exclue (120.4(1)(e)(ii))


✓ Founder

X Spouse

✓ Child 1 (25+)

~ Child 2 (18-24)

X Child 3 (minor)

> 17 years old

✓ Individual is actively engaged on a regular, continuous and

substantial basis in the activities of the business in the

current year or any 5 prior taxation years

− Depends on the facts and circumstances

− 120.4(1.1)(a): Deeming rule where individual works at

least an average of 20 hours per week during the

portion of the year in which the business operates

− Any 5 prior taxation years of the specified individual

12



Excluded Amount – Excluded shares / Actions exclues

(120.4(1)(g)(i))


~ Founder

X Spouse

X Child 1 (25+)

X Child 2 (18-24)

X Child 3 (minor)

> 24 years old

Shares owned by the specified individual if:

a) (i) Less than 90% of the business income of the

corporation was from the provision of services

(ii) the corporation is not a professional corporation

(accountant, dentist, lawyer, medical doctor,

veterinarian or chiropractor)

b) the specified individual owns shares that represent

10% or more of the votes and FMV

c) all or substantially all of the income for the year is not

derived, directly or indirectly, from one or more other

related businesses other than a business of the

corporation

13



Excluded Amount – Safe Harbour Capital Return / Rendement

exonéré (120.4(1)(f)(i))


X Founder

X Spouse

X Child 1 (25+)

~ Child 2 (18-24)

X Child 3 (minor)

18-24 years old

Return up to the highest prescribed rate of interest in effect for a

quarter in the year

• 2% as of April 2018

FMV of property contributed in support of the related business

• Pro rata according to the number of days in the year that

the property (or substituted property) is used in support of

the business

• Within the safe harbour: TOSI does not apply

• Amount exceeding the safe harbour: TOSI does apply

14



Excluded Amount – Reasonable Return / Rendement raisonnable

(120.4(1)(g)(ii))


✓ Founder

X Spouse

✓ Child 1 (25+)

X Child 2 (18-24)

X Child 3 (minor)

> 24 years old

✓ Amount derived directly or indirectly from a related business

✓ Reasonable having regard to the relative contributions of the

specified individual and each source individual in support of

the related business

a) Work performed

b) Property contributed

c) Risks assumed

d) Historical payments

e) Other relevant factors

• Reasonable amount: TOSI does not apply

• Unreasonable amount: TOSI does apply

15



Excluded Amount – Reasonable Return Arm’s Length Capital /

Rendement raisonnable – capital indépendant (120.4(1)(f)(ii))


X Founder

X Spouse

X Child 1 (25+)

X Child 2 (18-24)

X Child 3 (minor)

18-24 years old

Reasonable Return

Limited to contributions of arm’s length capital, being property

contributed by the specified individual that was not

− Derived, directly or indirectly, from a related business

− Borrowed under a loan or indebtedness

− Transferred, directly or indirectly by any means

whatever, from a related person (other than as a

consequence of death)

• Reasonable amount: TOSI does not apply

• Unreasonable amount: TOSI does apply

16


Upon the Sale of Opco and/or Holdco

Excluded Amount

• Capital gain realized on the disposition of shares that qualify as excluded shares

• Capital gain realized on the disposition of an excluded business

• Capital gain realized on the disposition of a non-related business

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Upon the Sale of Opco and/or Holdco

Excluded Amount – QFFP or QSBC (120.4(1)(d))

• No age limitation

• A taxable capital gain from the disposition of qualified small business corporation

(“QSBC”) shares and qualified farm or fishing property (“QFFP”) will not be subject

to TOSI

− Preserves the availability of the lifetime capital gains exemption (“LCGE”)

• This exception is not applicable to a taxable capital gain that is deemed to be an

ineligible dividend under subsection 120.4(4) or (5) – minors only

− Deemed dividend is subject to highest individual tax rate but dividend tax credit

is not denied

− The LCGE will be available to minors if there is a disposition to an arm’s length

party

− The LCGE will be available to minors if a capital gain arises as a consequence

of death

18


Upon the Breakdown of a Marriage or

Common-law PartnershipExcluded Amount – The Break-up Exception (120.4(1)(b))


• Property acquired by a spouse following the breakdown of a marriage or common-

law partnership

• The income derived from said property will not be subject to TOSI

− Decree, order or judgement of a competent tribunal or a written separation

agreement; and

− The taxpayer and their spouse or common-law partner were separated and

living apart as a result of the breakdown of their marriage or common-law

partnership

19


Example

Settlor: 3rd party

Trustees: Founder

3rd party non-settlor, non-beneficiary

Beneficiaries:

• Founder (source individual and specified individual)

• Spouse (specified individual)

• Child 1 (25 +) - full time (source individual and

specified individual)

• Child 2 (18-24) - part time (specified individual)

• Child 3 (minor) (specified individual)

• Corporations controlled by Founder

20


Upon the Retirement of Founder (+65 years

old)

• Founder (see previous slides)

• Excluded business

• Reasonable return – Does this still apply?

• Spouse

• No excluded amount exceptions are applicable

• “Baby Boomer Exception” (120.4(1.1)(c)(i))

✓ Founder is +65 years old

✓ TOSI does not apply to Founder due to an excluded amount

✓ TOSI will not apply to the spouse or common-law partner of Founder

21


Upon the Retirement of Founder (+65 years

old)

• Child 1 (25+) (see previous slides)

• Excluded business

• Reasonable return

• Child 2 (18-24) (see previous slides)

• Excluded business?

• Safe Harbor Capital Return?

• Child 3 (minor) (see previous slides)

• No excluded amount exceptions are applicable

22


Upon the Death of Founder

Excluded Amount – Capital gains on death (120.4(1)(c))

• Founder


• Taxable capital gains realized upon death are not subject to TOSI

23



Excluded Amount – Inheritance (120.4(1)(a))

SPECIFIED INDIVUDAL

(HEIRS)EXCLUDED AMOUNT – INHERITANCE EXCEPTIONS

Children < 25 years • Income from property inherited from a parent

Others < 25 years • Income from property inherited from anyone if full-

time student enrolled in a post-secondary

institution or eligible for the disability tax credit

24



Other Inheritance Exceptions – Continuity Rules

SPECIFIED INDIVIDUAL

(HEIRS)EXCLUDED AMOUNT – INHERITANCE EXCEPTIONS

Children > 17 years

Others > 17 years

(120.4(1.1)(b))

• Continuity rule for inherited property

− Reasonable Return: contributions of the deceased

will be those of the heir

− Excluded Business: if the deceased was actively

engaged on a regular and continuous basis, the

heir will be deemed to be as well

− Excluded Shares: if the deceased held excluded

shares, the heir will be deemed to have attained

age 24 before the year

Income earned from inherited property will not be

subject to TOSI

25



Other Inheritance Exceptions – Continuity Rules

SPECIFIED

INDIVIDUAL (HEIRS)EXCLUDED AMOUNT – INHERITANCE EXCEPTIONS

Spouse

(120.4(1.1)(c)(ii))

• Continuity rule for inherited property

− Income earned from inherited property will

qualify as an excluded amount for the spouse if

it was an excluded amount for the deceased

26


Recent Technical Interpretations

27


8 May 2018 Roundtable, 2018-0745871C6 – CALU

Conference Question 6 – Tax on Split Income• Excluded Amount – Excluded Shares

• Question 6(a): What is included as income from the

provision of services?

• Whether a business will be considered to be engaged in the provision of

services will depend of the facts and circumstances of the business

• Question 6(b): Can shares of a holding corporation qualify

as excluded shares?

• The definition of excluded shares should generally not include shares of a

holding company because, in the case of a holding corporation, all or

substantially all of the income would be derived from a related business

(other than a business carried on by the holding corporation)

28


May 29, 2018 – STEP Q. 5 – Split Income – Definition of

“excluded shares”

• What does “income” and “business income” mean?

• Distinction to be made between “business income” (para. (a)(i) of excluded

shares) and “income” (para. (c) of excluded shares)

• Business income will depend on the facts and circumstances

• Income refers to any source of income

• Generally means GROSS income

• What if a corporation has income from the provision of both

services and non-services?

• The income should be computed separately

• The non-service income should be taken into account in determining whether

shares are excluded shares

• UNLESS the income can reasonably be considered to be necessary but

incidental to the provision of the services

29


May 29, 2018 – STEP Q. 6 – Split Income – Can shares

of a Holdco qualify as “excluded shares”?

• Can shares of a holding company qualify as excluded shares?

• Generally, no, since all or substantially all of the income [of Holdco] is derived

from a related business [Opco] (other than a business of Holdco).

• CRA confirms that, although the excluded shares exception does not apply,

another exclusion can apply.

• Example: TOSI will not apply if it is a non-related business or an excluded

business of the specified individual or if the income constitutes a

reasonable return.

• However, CRA indicates that “the most appropriate test” to determine the

non-application of TOSI should be based on the general test of whether the

amount received is a reasonable return.

30


May 29, 2018 – STEP Q. 7 – Split Income – Excluded

shares and business income

• If a corporation does not have any business income, can its

shares qualify as excluded shares?

• No

• Condition in subpara. (a)(i) states that less than 90% of the business income is

from the provision of services; therefore, the corporation must have business

income to test

• (Services Income) < 0.9 (Business Income)

• If both services income and business income = zero, the condition has been

failed.

31


October 2018 – APFF Roundtable – Q. 9 – Excluded

shares

Question 9(a): Can shares of a Holdco qualify as excluded

shares?

> If Holdco carries on a business: the shares of Holdco may qualify as excluded

shares

• “Business” is not defined but the concept can expand to the undertaking of any

kind (248(1))

• The principal purpose of a business may be to derive income from property

(interest, rents, dividends, royalties)

> If Holdco does not carry on a business: the shares of Holdco cannot qualify as

excluded shares

• If income from Holdco does not derive directly or indirectly from a related

business, TOSI does not apply (non-related business exception)

32



shares

• Question 9(b) and (c)

Opco

Holdco

Mr.Mrs.

33



shares

Question 9(b)

• Holdco’s only revenue in the year derives from dividends from Opco

• Mrs. X would not own excluded shares because all or substantially all of Holdco’s

income derives from a related business (Opco)

• Again, CRA states that, although the excluded shares exception does not apply,

another exclusion may apply

34



shares

Question 9(c)

• Holdco owns passive investments acquired many years ago using dividends

received from Opco

• If Holdco carries on a business which earns income derived from property, the

shares held by Mrs. X would be excluded shares, “notwithstanding that the capital

used in the acquisition of property used in carrying on the business of Holdco was

derived from Opco” (condition (c) is met)

• Income of Holdco was not derived, directly or indirectly, from one or more related

business but rather derived from the business carried on by Holdco

• CRA will consider GAAR if transactions are effected so that shares qualify as

excluded shares to avoid 120.4

35


October 2018 – APFF Roundtable – Q. 10 –

Discretionary trust interests and s. 120.4 “related

business” valuation

• Property referred to in cl. (c)(i)(B) of the related business definition includes:

• shares of a corporation

• interest in a partnership

• interest in a trust (regardless of whether the trust is discretionary or not)

• Question of whether all or part of the FMV of a property is derived, directly or

indirectly from shares is a question of fact

• The determination of the FMV of an interest in a discretionary trust is a question of

valuation

36


October 2018 – APFF Roundtable – Q. 11 – Tracing

dividends paid by Holdco to stock portfolio rather than

related business

Opco

ParentHoldco

Kid

Holdco Income:

150 K passive investments

100 K Opco dividendC/S

P/S

37


October 2018 – APFF Roundtable – Q. 11 – Tracing

dividends paid by Holdco to stock portfolio rather than

related business

• Is the dividend from Holdco to Kid subject to TOSI?

• Holdco must adequately monitor its funds derived from Opco and funds derived from its

portfolio in order to determine which funds are used to pay a dividend

• If funds derive from Opco:

• Dividend would derive directly or indirectly from a related business

• If funds derive from portfolio:

• If Holdco carries on a business:

• Business would not qualify as a related business – there is no source

individual who is active in Holdco or has significant ownership of Holdco

• TOSI does not apply

• If Holdco does not carry on a business:

• There is no related business

• TOSI does not apply

38


October 2018 – APFF Roundtable – Q. 12 – 120.4 non-

application to partnership holding listed shares

• Family partnership that generates and distributes passive income from stock market

investments to Parents and Children

• Children have not contributed to or been involved in the Partnership, compared

to Parents who communicate with broker four times per year

• Is the partnership income subject to TOSI?

• There is no split income:

• dividend income or capital gain received by any of the partners

• in respect of shares:

• listed on a designated stock exchange, or

• of a mutual fund corporation

• CRA will review the application of various provisions

39


October 2018 – APFF Roundtable – Q. 13 – Split

income tax and distribution of reinvested capital gain

Portfolio generated $150,000 passive income. Holdco will pay a $100,000 dividend

on a prorata basis (directly to individuals and indirectly via the Trust)

Holdco

Kid X (minor)Mr. Mrs.

Kid Y (22)

40




• Trust sold shares of an Opco and allocated the capital to the family. They each

claimed LCGE

• Parents and Children acquired shares of Holdco using capital from the Trust

• Holdco used the subscription proceeds to acquire an investment portfolio

• Holdco pays dividend to its shareholders from the income earned from the portfolio

• Does TOSI apply to the dividends received by Mr., Mrs., Kid X and Kid Y from

Holdco or from a trust distribution?

41




• Kid X (minor) – TOSI applies

• Kid Y, Mr. and Mrs. (adults)

• If Holdco does not carry on a business

• TOSI does not apply to a dividend received from Holdco or from a

trust distribution (non-related business exception)

• If Holdco does carry on a business

• Non-related business exception does not apply

• Kid Y: Safe Harbour Capital Return exception might apply to a

dividend received from Holdco or from a trust distribution

• Mr. and Mrs.: Excluded shares exception might apply to a dividend

received from Holdco and Reasonable return exception might apply

to a dividend received from a trust distribution

42


October 2018 – APFF Roundtable (Financial strategies

and instruments) – Q. 2 – Excluded shares and TOSI

> CRA comments on Q.7 from the STEP Roundtable as well as example 10 and 12

from the CRA guidelines

> Exclusions are applicable not only to entities that carry on an active business but

also to entities that carry on a business whose principal purpose is to derive

income from property (assuming that there is a sufficient level of activity)

> Answer mirrors Q. 9(a) APFF Roundtable

> If Holdco carries on a business: the shares of Holdco may qualify as excluded

shares

> If Holdco does not carry on a business: the shares of Holdco cannot qualify as

excluded shares

43



and instruments) – Q. 3 – Testamentary trust and TOSIFacts

• Life insurance proceeds and stock market investments are left to a Testamentary

Spousal Trust, whereby the spouse of the deceased is the sole beneficiary and the

children are trustees

• Trust generates passive income (dividends, capital gains and interest on bonds)

Question

• Under different management scenarios, will the passive income distributed to

Spouse subject to TOSI?

Response

• Do the different sources of income qualify as split income – is it reasonable to

consider that it derives directly or indirectly from a related business?

• Dividends and capital gains: derived from public corporations; therefore, not split

income and TOSI does not apply

• Interest: split income ? Derived directly or indirectly from a related business? If so,

do any inheritance/ continuity rules apply?

44



and instruments) – Q. 4 – Trusts, rental income and

TOSIFacts

• Testamentary spousal trust owns five commercial rental properties, which were

previously managed by the deceased

Question

• Under different management scenarios, will the rental income distributed to Spouse

subject to TOSI?

Response

• Does the rental income qualify as split income – is it reasonable to consider that it

derives directly or indirectly from a related business?

• Does the trust carry on a business? Is a source individual actively involved in the activities

of the trust?

• If so, an inheritance/ continuity rule can apply such that the income would be

deemed to be an excluded amount for the Spouse (since the income would have

been an excluded amount to the deceased [120.4(1.1)c)(ii)])

45



and instruments) – Q. 15 – TOSI – excluded shares and

business income

• CRA confirms that if a corporation does not have business income,

its shares cannot qualify as excluded shares (reiterates STEP, Q.

7)

46


May 25, 2018 – 2018-0761601E5 – Tax on Split Income

• General comments provided related to the definition of excluded

shares and excluded business

47


July 6, 2018 – 2018-0759521E5 – Tax on split income

and preferred beneficiary

• CRA confirms that the definition of split income includes trust

distributions but not preferred beneficiary amount under s. 104(14)

48


August 21, 2018 – 2018-0771811E5 – Excluded shares

– 10 % or more Votes & Value Test

• For the purpose of the vote & value test in para. (b) of the definition

of excluded shares, ownership of multiple classes of shares should

be considered.

49


September 26, 2018 – 2018-0770911E5 – Revised

income sprinkling rules• CRA states that a shareholder-spouse may be exempt from TOSI

under the excluded business exception if the spouse does not work

for a portion of the year due to birth or adoption of a child –

sufficient involvement can still be proven even if the 20-hour test is

not met. Same may be true in case of illness.

• CRA does not comment on application of excluded shares

exception due to insufficient details.

50


November 2, 2018 – 2018-0771861E5 – TOSI and the

meaning of “derived directly or indirectly from a

related business”

• Facts

Will dividend income be considered to derive directly or indirectly from a related

business in the following scenarios:

Investco

Mr. Mrs.

Opco

51


November 2, 2018 – 2018-0771861E5 – TOSI and

the meaning of “derived directly or indirectly from

a related business”1. If Investco pays all of the dividend income from the publicly traded

corporations to Mrs:

• If Investco does not carry on a business : non-related business exception

would apply and, therefore, TOSI would not apply

• If Investco does carry on a business : non-related business exception would

not apply and we would need to determine if another exception could apply.

52




a related business”2. If Investco pays a dividend in kind to Mrs and transfers the portfolio to

Mrs:

• Y1 Opco dividend to Investco = $1M and Investco acquires the Portfolio

• Y2 Holdco pays dividend in kind = $1.1M

• The portion of the FMV of the portfolio that represents the initial investment

of the Opco dividends ($1M) would be considered to be derived, directly or

indirectly, from a related business of Opco – non-related business exception

does not apply

• If Investco does not carry on a business:

• The portion of the gains (100K) would not be considered to be derived,

directly or indirectly, from a related business of Opco or Investco – non-

related business exception applies

• If Investco does carry on a business: non-related business exception would not

apply and we would need to determine if another exception could apply.

53




a related business”

3. If all the dividends from Opco to Investco we paid prior to new

TOSI (pre-2018), would the answers be different:

• Conclusions above would not change

54


November 2, 2018 – 2018-0771851E5 – Meaning of

“reasonable return”

Loan has now been repaid by Xco to Mr. and Mrs.

Xco

Mr. Mrs.

Start-up capital:

mortgage proceeds loaned by

Mr. and Mrs.

55



“reasonable return”• Q.1: If Mr. receives a dividend from Xco, would the reasonable return

exception apply to him in regards to the risks he initially assumed on

the start-up of Xco’s business ?

• CRA would consider the fact that both Mr. and Ms. risked their family home by

mortgaging it in order to provide the Loan to Xco

• CRA would also consider if they were both adequately compensated for taking

the risk, based on the terms and conditions of the Loan

• If the terms of the Loan were not sufficient, the relative risk assumed could be

taken into account in determining whether a dividend received by Mr. X after the

repayment of the Loan is a reasonable return

56



“reasonable return”

• Q.2: Can Mr. look at the undistributed retained earnings of Xco as

capital that is at risk for purposes of this exception?

• The undistributed retained earnings of Xco do not represent capital

contributed directly or indirectly by either of Mr. or Ms.

• This factor is not relevant in assessing their relative contributions to the

related business carried on by Xco

57


Conclusion

• TOSI seems to apply as a general rule, subject to various

exceptions

• The exceptions are not mutually exclusive

• Income splitting opportunities are limited but not impossible

- Depends on the age of the specified individual

- Depends on the type of income earned by the specified individual and/or the

entity carrying on the business

- Depends on type of business …… and the existence of a business

- Depends on the contributions in support of the business

- Depends on different stages of life of the specified individual and the entity

carrying on the business

58


Conclusion

• Implementing a freeze

− Remains an important estate planning measure for the freezor

− Remains an important tool in the integration of future generations and key

employees (either through a trust or direct ownership)

• Trusts

− Creditor protection benefit remains

− Family dynamic consideration still relevant

− Multiplication of LCGE remains

• The landscape is ever-changing!

59


Merci / Thank you !

KATHERINE BORSELLINOLL.B, J.D., LL.M (FISC.)

Manager, Tax

T.514.934.3469

[email protected]

EMILIECHAMPAGNE-COUILLARDLL.B, D.E.S.S. (FISC.)

Associate, Tax

T.514.934.3440 – 4710

[email protected]

RICHTER

the tosi rules - ctf pp 2018/tosi.pdf · 5 the tosi rules –what’s new? tosi –application •...

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