In 2017, the Federal Liberal Government introduced a very complicated tax on split income (TOSI) that changed this basic principle. Under the new TOSI rules, some people will pay the regular rates of tax and some people will pay the highest possible rate even if they earn exactly the same amount.
The prescribed rate used to calculate taxable benefits for employees and shareholders for interest-free and low-interest loans has been 1%, the lowest possible rate, since April 2009, other than in Q4 2013 when it rose to 2%.
On July 18, 2017, the Department of Finance released its much-anticipated consultation paper, “Tax Planning Using Private Corporations”, announced in the 2017 federal budget (the “consultation paper”). The consultation paper, along with the draft legislation released therewith, contain a number of fundamental changes to the taxation of private corporations and family trusts.