Participants will examine how the small business deduction (SBD) operates within private corporate groups, including the effects of related/associated/affiliated relationships, specified partnership income (SPI), specified corporate income (SCI), and business-limit grind mechanisms. Participants will apply a structured framework to diagnose SBD eligibility and optimize group structures, dividends, and inter-company arrangements.

Note: This seminar does not include a review of Section 55, Safe Income or GST/HST as additional courses on these topics are available.

• Tax practitioners and accounting professionals who advise groups of privately held companies. 
• Professionals seeking a practical framework to navigate SBD access across multi-entity structures. 

By the end of this course, participants should be able to: 

• Explain SBD requirements, rates, and limits for CCPCs and identify the types of income that qualify. 
• Apply related, associated, and affiliated rules to common group structures and determine SBD consequences. 
• Identify when SPI and SCI rules apply and evaluate their impact on a group’s SBD access. 
• Assess business-limit reductions driven by taxable capital and adjusted aggregate investment income (AAII) and outline mitigation approaches.  

Topics include: 

• The SBD: eligibility, income types, and key requirements for CCPCs. 
• Relationships in corporate groups: related, associated, and affiliated rules; look-through concepts; options/rights; control by value; deemed association. 
• SBD business-limit reductions: taxable capital grind, AAII interaction, anti-avoidance touchpoints, and worked mini-cases. 
• Partnerships in a group: SPI rules (legacy and current), designated members, specified partnership business limit, timing issues, and anti-avoidance. 
• SCI framework: definition, 90% exception, assignments, association exception, timing, and application to incorporated partnerships. 
• Part IV tax in groups: connected-corporation concepts and trust interactions (corporate beneficiaries, subsection 75(2), and related considerations). 
• Other common issues: domestic transfer pricing within groups, GST/HST closely related elections, and loss-utilization/stop-loss highlights.  

Course Content Created: October 2025

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About This Product

On-Demand Courses by CPA PRO are either video recordings from live seminars, or video recordings produced specifically for the on-demand audience. Where available, accompanying materials such as handouts or course notes are included.On-demand courses are eligible for verifiable CPD hours upon successful completion, and a certificate will be made available for download for your records.

Note that some courses comprise both formal instruction and self-directed exercises. In such cases, participants must complete both components to claim full CPD hours, or must reduce their reported CPD hours accordingly.

Please note that not all on-demand courses include downloadable materials such as course notes or slides.

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