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Physician guide · 2026
Family shares in your medical corporation: what still works.
Ontario lets a physician's spouse, children and parents hold non-voting shares in a medicine professional corporation. Since 2018, the tax on split income (TOSI) taxes most dividends paid to them at the top rate. The shares are still worth having, for different reasons than before.
Who can own what
The Ontario rules.
- Voting shares: only physicians who are members of the CPSO.
- Non-voting shares: the physician's spouse (including common-law), children and parents, directly, or a trust for minor children.
- Directors and officers: physician shareholders.
- The CPSO counts step-children and step-parents as family; parents-in-law are not eligible.
What TOSI changed
Dividends paid to a family member who is not actively involved in the practice are taxed at the top personal rate, which removes the benefit of splitting. The main exceptions that matter to physicians:
- Age 65. Where the physician has turned 65 before the year, dividends to a spouse can be excluded from TOSI. It is the big one for retirement planning, but it is conditional rather than automatic — the test asks whether the amount would be an excluded amount in the physician's own hands — and it applies to a spouse only. Adult children and parents stay caught indefinitely.
- Actively engaged. A family member aged 18 or over who works in the business an average of 20 hours a week, this year or in any five earlier years, is excluded.
- Not available: the “excluded shares” exception does not apply to professional corporations.
What still works
Reasonable salary for real work. A spouse who manages the office or does the books can be paid what you would pay a stranger for the same work. It is deductible to the corporation and outside TOSI.
Spousal RRSP. Contributions from your salary, withdrawn later in the spouse's hands.
Shares in place for 65. Issuing non-voting shares to a spouse now means the structure is ready when the age-65 exception opens.
Estate planning. Family shareholdings and insurance inside the corporation are part of the long-term plan.
Quick answers
What physicians ask about family shares.
Can my spouse own shares in my medicine professional corporation?
Yes. In Ontario a physician's spouse, children and parents can hold non-voting shares, and a trust can hold them for minor children. Voting shares must be held by physicians.
Can I pay dividends to my spouse to split income?
Generally not until you turn 65, and even then the relief is conditional on the facts of that year. Before then, dividends to a spouse who is not actively engaged in the practice are taxed at the top rate under the tax on split income rules. The age-65 relief is for a spouse only.
Is paying my spouse a salary allowed?
Yes, if the work is real and the pay is reasonable for that work. Keep a job description and records of hours.
Can my adult children receive dividends?
Only without TOSI if they are actively engaged in the practice, working an average of 20 hours a week. Otherwise the dividend is taxed at the top rate.
Sources: CPSO incorporation FAQ; CRA guidance on the tax on split income. General information, not advice for your situation. See also salary versus dividends.
Want your share structure reviewed?
Call 647-870-8498 or email info@ghayurtax.com. We will check who holds what and whether it still fits.