This articles review the interaction of the subsection 82(3) election and the TOSI rules. “[I]n the CRA’s view, the correct method of applying the two provisions is to allocate receipt of the dividends in accordance with subsection 82(3) and then apply the TOSI regime.”
P Friedlan and A Friedlan “The Interaction Between the Subsection 82(3) Election and TOSI” 22:1 Tax for the Owner-Manager (Jan 2022)
