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Ontario CCPCs  ·  Subsection 125(5.1)  ·  Free Calculator

Passive Income SBD Grind Calculator for Ontario CCPCs

Investment income above $50,000 grinds your small business limit by $5 for every $1. But Ontario never adopted that rule, so the cost in Ontario is far smaller than almost every calculator online will tell you. Work out the real number.

Ontario does not parallel the grind
New 2.2% provincial rate
Taxable capital grind included
Associated group aggregated

Step 1 — The Corporation

Income from the operating business, before tax


Across the associated group. A separate grind starts at $10,000,000.

2027 onward

2027 onward
Calendar 2026

Ontario’s small business rate fell to 2.2% on 1 July 2026

Step 2 — Adjusted Aggregate Investment Income, Prior Year

Bank interest, GICs, bonds, shareholder loans receivable


The taxable half only, net of allowable capital losses of the year


After expenses. Rental income is investment income unless you have more than five full-time employees.


From corporations you are not connected with. Dividends from connected corporations are excluded.


The whole group is aggregated, so a separate holdco does not help

Your Position


extra tax a year

Adjusted Aggregate Investment Income

Federal Limit Remaining

Ontario Limit Remaining

Extra Tax Per Year

How the Grind Is Calculated

StepBasisAmount

Federal and Ontario Treated Separately

ItemFederalOntario

The Rate That Actually Applies

IncomeFederalOntarioCombined

What the Grind Costs You

PositionBasisCorporate Tax

Corporate Tax With and Without the Grind

If investment income stayed under $50,000
On your actual figures

Points That Decide This

    What to Do Next

    Disclaimer: Subsection 125(5.1) reduces the $500,000 business limit by $5 for every $1 of adjusted aggregate investment income above $50,000 in the prior taxation year, across the associated group, eliminating the limit entirely at $150,000. Ontario does not parallel this measure, so the Ontario small business limit is unaffected by passive income. Ontario does parallel the taxable capital reduction, which phases the limit out between $10,000,000 and $50,000,000 of taxable capital employed in Canada, and the federal reduction is the greater of the two rather than the sum. Rates used are 9% federal small business, 15% federal general, 11.5% Ontario general, and an Ontario small business rate of 2.2% from 1 July 2026, shown as a day-weighted 2.696% for calendar 2026 corporations. Adjusted aggregate investment income excludes dividends from connected corporations and income from an active business. This page is general information, not tax advice.

    Ontario Never Adopted the Grind

    The federal rule is well known. Adjusted aggregate investment income above $50,000 reduces the $500,000 business limit by $5 for every $1, wiping it out entirely at $150,000.

    What almost every calculator and article gets wrong is the consequence in Ontario. Ontario chose not to parallel the measure, so the Ontario small business limit is not touched by passive income at all. Only the federal portion is lost.

    IncomeFederalOntarioCombined
    Within the small business limit9%2.2%11.2%
    Ground out by passive income15%2.2%, unchanged17.2%
    Above the $500,000 limit entirely15%11.5%26.5%

    The grind costs an Ontario CCPC 6 percentage points, not 15.3. Ground income is taxed at 17.2%, not 26.5%, because the Ontario small business rate survives untouched. On a fully ground $500,000 limit that is $30,000 a year rather than the $76,500 most sources imply. Still worth managing, but nowhere near the crisis it is usually presented as.

    Ontario Also Cut the Rate

    Ontario reduced its small business rate from 3.2% to 2.2% effective 1 July 2026, so the combined small business rate is now 11.2% rather than the 12.2% you will still see quoted almost everywhere.

    Corporations with a year straddling that date use a day-weighted rate. A calendar-year corporation pays 2.696% provincially for 2026, giving a combined 11.696%, and the full 11.2% applies from 2027.

    What Counts as Adjusted Aggregate Investment Income

    IncludedExcluded
    Interest on cash, GICs and bondsDividends from connected corporations
    The taxable half of capital gainsIncome from an active business
    Net rental incomeCapital gains on active business assets used in the business
    Portfolio dividends from unconnected corporationsCapital gains on shares of a connected active business corporation
    Royalties on passive propertyThe non-taxable half of capital gains

    Two exclusions matter more than the rest. Dividends moving up from an operating company to a holding company are not investment income for this purpose, so a properly structured group does not grind itself simply by sweeping surplus upward. And a capital gain on selling the operating business itself is generally excluded, which protects the year of a sale.

    It Is the Prior Year That Counts

    The grind applies to the current year’s business limit based on the previous year’s investment income. That makes it manageable in a way most rules are not, because you know a year in advance whether the limit is coming down.

    It also means a one-off gain has a delayed effect. Selling a portfolio position in December affects next year’s limit, not this year’s, and a large realised gain in one year can be planned around before it bites.

    A Separate Holding Company Does Not Help

    The whole associated group is aggregated. Moving the investments into a holdco does not reduce the grind, because the investment income of every associated corporation counts toward the same $50,000 threshold and the group shares one $500,000 limit. Holdcos are worth having for creditor protection and succession. They do nothing at all for this.

    The Taxable Capital Grind Runs Alongside

    A second reduction phases the business limit out between $10,000,000 and $50,000,000 of taxable capital employed in Canada across the associated group. Ontario does parallel this one, so it reduces both the federal and the Ontario limits.

    Where both apply, the federal reduction is the greater of the two rather than the sum. A corporation with $30,000,000 of taxable capital loses $250,000 of limit federally and provincially, which costs considerably more than the passive grind because the Ontario side goes with it.

    What Actually Reduces the Number

    • Corporate class and total return funds that defer distributions, so income is realised when you choose rather than annually.
    • Realising gains deliberately, spreading them across years rather than bunching them.
    • Exempt life insurance, where the growth is not investment income at all.
    • Paying out surplus as dividends and investing personally or in a family trust, though that accelerates personal tax.
    • An individual pension plan, which moves investment growth outside the corporation entirely.
    • Timing the year of sale, since a large gain affects the following year’s limit.

    Sometimes the Right Answer Is to Do Nothing

    At a 6 point cost, a fully ground limit costs $30,000 a year in Ontario. If the investment portfolio generating that passive income is earning more than $30,000 of additional return by staying invested where it is, restructuring around the grind destroys value rather than creating it.

    That calculation is worth doing before paying for a solution to it. In Alberta or British Columbia, where the provincial grind does parallel, the answer is often different.

    What This Calculator Does Not Cover

    • Provinces other than Ontario, most of which do parallel the federal grind
    • The allocation of the business limit between associated corporations on Schedule 23
    • Foreign accrual property income and its interaction with the calculation
    • Refundable tax and the dividend refund, which run alongside this
    • Specified corporate income and the separate limit reduction for services to associated corporations
    • The year of a business sale, where several exclusions can apply at once

    Know the real number before restructuring around it. In Ontario the grind is a 6 point cost, not the 15 point cost usually quoted, and that changes what is worth doing about it. Our holding company planning service covers the group structure, the limit allocation and the investment income position.

    Frequently Asked Questions

    Common questions from Ontario CCPC owners with corporate investments.

    How much passive income can my corporation earn before losing the small business rate?
    Federally, $50,000 of adjusted aggregate investment income in the prior year. Above that the $500,000 business limit falls by $5 for every $1, and disappears entirely at $150,000. In Ontario the provincial small business limit is not reduced at all, because Ontario chose not to parallel the federal measure.

    Does the grind really take me from 12.2% to 26.5%?
    Not in Ontario, and this is the most common error on the subject. Ground income is taxed at 15% federally but keeps the Ontario small business rate of 2.2%, giving 17.2% rather than 26.5%. The combined small business rate is also 11.2% now rather than 12.2%, following Ontario’s rate cut on 1 July 2026. So the grind costs 6 percentage points in Ontario, not 15.3.

    What does the grind actually cost in dollars?
    On a fully ground $500,000 limit in Ontario, $30,000 a year. That is the 6 point difference between 11.2% and 17.2% applied to the whole limit. Worth managing, but considerably less than the $76,500 that a 26.5% assumption would suggest, and small enough that restructuring is not automatically worth it.

    What counts as adjusted aggregate investment income?
    Interest, the taxable half of capital gains, net rental income, portfolio dividends from corporations you are not connected with, and royalties on passive property. Excluded are dividends from connected corporations, income from an active business, and capital gains on assets used in an active business or on shares of a connected active business corporation.

    Will moving my investments into a holding company avoid the grind?
    No. The investment income of every associated corporation is aggregated against the same $50,000 threshold, and the group shares one $500,000 limit. A holding company is worth having for creditor protection, succession and estate planning, but it does nothing whatsoever for the passive income grind.

    Is it this year’s investment income or last year’s?
    Last year’s. The current year’s business limit is reduced based on the prior year’s adjusted aggregate investment income, which means you always know a year ahead whether the limit is coming down. A large gain realised this December affects next year’s limit rather than this one, giving time to plan around it.

    Does rental income count?
    Yes, net rental income is investment income unless the corporation employs more than five full-time employees in the rental business throughout the year. That is a high bar which a single rental or a handful of units will not meet, so most corporate rental income counts toward the threshold in full.

    Should I restructure to avoid the grind?
    Only if the cost exceeds what the restructuring gives up. In Ontario a fully ground limit costs $30,000 a year. If the portfolio generating the passive income is earning more than that by being invested as it is, moving it destroys value. Run that comparison before paying for a solution, because in Ontario the problem is genuinely smaller than it is usually described.

    Know the Real Number Before You Restructure Around It

    Send us last year’s financial statements and the investment income detail. We will calculate the actual grind on your group, allocate the limit properly across associated corporations, and tell you plainly whether it is worth doing anything about.

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