Calvin C S Wong
Corporate Liquidity Planning
Structure surplus corporate cash more efficiently before your Adjusted Aggregate Investment Income (AAII) exceeds $50,000 and jeopardizes your Small Business Deduction.
Request a Corporate Liquidity Review
For Canadian-controlled private corporations, passive investment income can reduce access to the preferred federal small business tax rate. CRA guidance confirms that the business limit may be reduced once Adjusted Aggregate Investment Income enters the $50,000 to $150,000 corridor.
The passive-income business limit reduction generally begins once adjusted aggregate investment income exceeds $50,000.
CRA’s formula reduces the business limit by $5 for every $1 of AAII above the $50,000 threshold, subject to the corporation’s available business limit.
Once passive investment income exceeds $150,000, the federal small business limit is reduced to nil, moving affected active business income toward the general corporate rate.
Official References
This section summarizes federal corporate tax mechanics for educational purposes only. Provincial tax treatment, associated corporation rules, taxable capital limits, investment composition, and timing may affect the actual result. Review with a qualified CPA or tax advisor before acting.
A structural disconnect exists in how surplus corporate cash is managed across traditional advisory teams. The tax issue, investment account, and insurance structure are often reviewed separately — even though the corporate cash problem connects all three.
Accountants often see the passive-income tax issue first, but they usually do not implement the corporate insurance structures required to reposition retained earnings.
Banks may invest the corporate cash, but the portfolio discussion can miss the passive-income drag created when taxable investment income accumulates inside the corporation.
Traditional agents may present insurance products, but often fail to frame the larger corporate liquidity issue around retained earnings, tax drag, and long-term capital access.
The Planning Gap
Retained earnings, passive income, and corporate liquidity need to be planned together — not handled as disconnected tax, banking, and insurance conversations.
A quantitative review designed to determine whether retained earnings are creating passive-income tax drag — and whether a corporate-owned insurance structure may improve after-tax liquidity, long-term capital access, and shareholder planning.
Identify whether passive investment income is approaching or exceeding the Small Business Deduction clawback corridor.
Review whether surplus corporate cash is being held, invested, or distributed in a structure that creates unnecessary tax drag.
Assess whether a corporate-owned structure fits your cash flow, time horizon, liquidity needs, shareholder objectives, and insurance requirements.
If suitable, build the appropriate structure around corporate liquidity, tax efficiency, risk protection, and long-term capital planning.
Products are not the starting point.
They are only considered after the review confirms that implementation is suitable for the corporation.
There is no upfront consulting fee for the Corporate Liquidity Review. If a suitable insurance strategy is implemented, compensation is paid by the insurer through first-year and renewal commissions.
The review is designed to produce a clear planning decision before any product recommendation is made. Corporate-owned insurance is only considered after retained earnings, tax drag, liquidity needs, and shareholder objectives are understood.
The starting point is not a policy illustration. The review begins with retained earnings, passive-income exposure, corporate cash flow, tax drag, liquidity needs, and shareholder planning objectives.
The process is designed to complement your existing advisory team, not replace it. Tax-sensitive implementation should be reviewed with qualified accounting and tax professionals before action is taken.
If the structure does not make financial sense, the correct outcome is to not proceed. Suitability depends on cash flow, time horizon, insurance need, liquidity requirements, and shareholder goals.
The objective is not to prove that corporate-owned insurance is always the answer. The objective is to determine whether it is a suitable tool for your corporation.
The Corporate Liquidity Review is delivered through a team-based process combining analysis, suitability review, and structural implementation.
Corporate Liquidity Analysis / Review Framework
Develops and directs the retained earnings, AAII exposure, passive-income tax drag, and corporate liquidity review framework used to identify whether a case should move toward modelling.
Lead Advisor / Structural Implementation
Leads most client consultations and oversees the execution of suitable corporate-owned insurance strategies, including implementation, underwriting coordination, and liquidity planning.
The objective is a clean handoff from analysis to implementation — so incorporated professionals understand the planning logic before any structure is placed.
Before repositioning corporate surplus cash or implementing a corporate-owned structure, start with a review of tax drag, cash flow, liquidity needs, and planning suitability.
Request a Corporate Liquidity ReviewNo upfront consulting fee. Suitable implementation only.