Do Repaid Loans Get You Out of the TOSI Rules? CRA Says Maybe

In CRA interpretation no. 2018-0771851E5, the CRA was asked whether a shareholder who does not actively participate in the business could be exempt from the tax on split income (TOSI) rules on the basis that he or she lent the company money in the past, which has since been repaid by the company several years […]

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