CRA indicates that holding company shares do not qualify as excluded shares for TOSI purposes

CRA indicated that the definition of excluded shares should generally not include the shares of a Holdco, because all or substantially all of its income would be derived from a related business with respect to the individual. Thus, any income or taxable capital gains from the dispositio­­n of such shares will not be an excluded amount and will be split income of the individual subject to the tax on split income unless another exclusion applies, for example, if the related business is itself an excluded business.

Neal Armstrong. Summary of 29 May 2018 STEP Roundtable, Q.6 under s. 120.4(1) – excluded shares.