Justor Inc. is a Canadian private corporation that has operated a manufacturing business since 2012. During the period 2012 through 2019, all of the shares were owned by George Sessions. Also, during this period, George's son Gary worked full-time in the business, receiving a salary that was sufficient for him and his family to live comfortably. Both George and Gary live and work in Canada. In late 2021, George concludes that the business would benefit from his son having an MBA. In keeping with this view, in January 2022, Gary enrolled in an executive MBA program that will require two years to complete. In order to provide income for his son now that he is no longer working in the business, George has Justor issue to Gary a new class of shares that do not vote. In 2023, the plan is to pay dividends on these shares to Gary totalling $150,000. Will the dividend paid to Gary be subject to Tax on Split Income (TOSI)?

Make Your Own Prediction: indicate if you think Garys dividend will be subject to TOSI. Why or why not? Explain your conclusions.