CRA indicates that an excluded amount can exceed arm’s length remuneration for the services rendered

The spouse of a professional works over 20 hours per week as a part-time receptionist in the professional practice of her spouse's corporation (XCo). She does not receive a “market” salary for her services of $18,000, and instead receives an annual dividend of $150,000 on her non-voting preferred shares of XCo.

CRA indicated that since she satisfies the 20 hours per week test in s. 120.4(1.1)(a), her dividend income would be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income.

Neal Armstrong. Summary of 7 June 2019 STEP CRA Roundtable, Q.4 under s. 120.4(1.1)(a).