The dividend splitting (sprinkling is too Trumpy) proposals are simple in theory. In pracuce, the problem is that the term "reasonable" cannot be legislated, so a CRA auditor with a checklist will be sitting in boardrooms telling taxpayers what is.  Since evety fact situation is different, this will not end well.  If these proposals are implemented, look for Appeals and the courts to be clogged for years and an army of CRA hires big enough to eat up whatever revenue Mr Morneau thinks they will pull in.

There are so many time bombs in the capital gains/dividend arbitrage rules that it is hard to know where to start.  As one example of a depressingly long list, the proposals would make proceeds from life insurance policies taxable notwithstanding that the premiums were never deductible.  Many estates which have insured their death tax liabilities will now have roughly half of what they had planned and will have to liquidate assets.

The passive income proposals are, simply, unworkable.