TOSI and foreign affiliates

The TOSI rules don’t just apply to dividends from Canadian private corporations. The rules can apply to dividends from foreign private corporations as well, and the tax results are potentially horrendous.

Stan Shadrin, Manu Kakkar and Alex Ghani, “FAPI and TOSI Overlap: 107 Percent Tax Is Not Fair” (January 2020) 20:1 Tax for the Owner-Manager