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Corporate Tax & Owner Compensation

How should a business owner plan year-end compensation?

Plan it in a fixed order, before year-end rather than at filing time: first where corporate income lands against the $500,000 small business limit, then the salary-dividend mix against your personal cash need, then the shareholder loan account, then the passive-income and refundable-tax pools, and finally any income moving to family members. There is no universal right mix of salary and dividends. There is a correct sequence of questions, and most of the levers close on December 31.

Tax slips, a folder and a calculator laid out on a desk

Start with the corporation's number, not your own

The first year-end question is where corporate taxable income will land against the $500,000 small business limit, because that sets the price of every dollar you leave inside. In Ontario, a CCPC pays a combined 12.2% on its first $500,000 of active business income and 26.5% on active income above that. The gap between those rates, and the gap between both of them and your personal marginal rate, drives everything else in the plan.

Below the limit, retained profit is cheap to keep. Income taxed at 12.2% leaves nearly 88 cents on the dollar working inside the corporation, and the personal tax waits until you actually take the money out. That deferral is the single biggest advantage of running your business through a corporation, and a year-end plan that empties the company just to make the personal return look tidy is usually leaving value behind.

Above the limit, the old reflex was to bonus down to $500,000 so nothing was taxed at the general rate. It is no longer automatic. Income taxed at the general rate adds to the corporation's GRIP account, which lets it pay eligible dividends that are taxed at a meaningfully lower personal rate than ordinary dividends, so retaining general-rate income and paying eligible dividends later can beat the bonus. Whether it does is arithmetic on your numbers rather than a rule of thumb, and it is exactly the calculation that sits behind the small business deduction.

One mechanical rule shapes the bonus route. A bonus accrued at year-end is only deductible in that year if it is actually paid within 180 days after year-end, with source deductions withheld and remitted when it is paid. Miss the window and the deduction slides into the year of payment, which defeats the reason for accruing it.

Watch the two calendars if your corporation's year-end is not December 31. The corporate deduction follows the fiscal year, but salary and dividends are taxed to you by calendar year, so a June year-end corporation has two planning windows: one for the corporate side in the spring, another for the personal side in December. Plans that treat them as the same date routinely misfire by a bracket.

Salary and dividends do different jobs

Salary buys RRSP room and CPP and gives the corporation a deduction; dividends are simpler to run but build no retirement room. Salary is deductible against corporate income and taxed in your hands at ordinary rates, with income tax and CPP withheld every pay period. It creates RRSP room at 18% of earned income up to the annual dollar cap, and it funds both halves of your CPP contribution, which is a real cost this year and a real, indexed pension later.

Dividends come out of profit the corporation has already paid tax on, so there is no corporate deduction. Personally they are grossed up and credited, with eligible dividends paid out of GRIP taxed noticeably lighter than non-eligible ones. Nothing is withheld at source on a dividend, which feels pleasant in the year you receive it and less pleasant the following year when CRA starts asking for quarterly instalments.

The administrative load differs too, and it is not trivial. Salary needs a payroll account, withholding calculations, remittances on schedule and a T4 each February, with real penalties for remitting late. A dividend needs a directors' resolution and a T5. Neither is a reason to pick a route by itself, but the difference matters to owners running lean.

Integration is the tax system's attempt to make the two routes land in roughly the same place once corporate and personal tax are added together. It is close, not exact, and the differences that decide real plans are rarely the headline rate. They are RRSP room, CPP participation, the timing of tax, and what each choice does to the corporate accounts covered below.

Most owner-managers end up with a blend, and the blend should be recalculated every year rather than copied forward from last year. This is the core annual exercise a corporate tax planning CPA in Ontario runs each fall: your household cash need, the corporation's income level and its tax pools, solved together while there is still time to act inside the year.

Clear the shareholder loan account before it clears itself

If you have drawn cash from the corporation all year, those draws must be repaid or converted into salary or dividends on time, or the Income Tax Act converts them for you on the worst available terms. A shareholder loan still outstanding one year after the end of the corporation's taxation year in which you drew it is added to your personal income in full, with no matching corporate deduction. That is the most expensive form of compensation there is.

Until a balance is dealt with, an interest-free draw also generates a taxable interest benefit at the prescribed rate for every month it sits there. The year-end meeting is where each draw finally gets a label: this much becomes salary and runs through payroll, this much is declared as a dividend and lands on a T5, and this much is genuinely repaid from personal funds.

Repaying in December and drawing the same money back out in January does not work. A series of loans and repayments can be unwound, and the income inclusion applies as if the repayment never happened. If the account refills every single year, the real problem is that the compensation level is set below how you actually live, and the fix is the plan itself, not cleverer paperwork.

Passive income and refundable tax change the dividend math

Investment income inside the corporation is taxed at roughly 50% up front, but a large slice of that is refundable tax the corporation only recovers when it pays taxable dividends to you. The refundable slice accumulates in the RDTOH accounts and comes back at 38.33 cents for every dollar of taxable dividend paid, up to the balance in the pool. A corporation sitting on a meaningful RDTOH balance has a standing reason to pay dividends before year-end, because every dollar of that dividend is partly financed by the refund.

Passive income also reaches forward and grinds the small business deduction. Once adjusted aggregate investment income across the corporate group passes $50,000 in a year, the following year's $500,000 limit shrinks by $5 for every additional $1, and it is gone entirely at $150,000. A corporation carrying a large investment portfolio can find its active income taxed at 26.5% from the first dollar, without anyone having decided that on purpose.

Year-end compensation interacts with both mechanisms. Paying salary lowers corporate income but does nothing about investment income. Paying dividends releases refunds and moves retained cash out of harm's way. Realizing or deferring gains in the corporate portfolio moves the investment-income number itself, so the compensation plan, the portfolio and the CCPC tax pools are one system, and deciding one without looking at the other two is how corporations quietly lose their 12.2% rate.

One more account is worth checking before December: half of any capital gains the corporation has realized sits in the capital dividend account, which can be paid out entirely tax-free by election. A year with realized gains in the corporate portfolio often supports a tax-free layer in the compensation mix, and a planned capital loss shrinks that account if it is realized before the election rather than after. Sequencing the trades and the election is a detail that pays for the whole meeting.

Owner-level planning covers the household, not just the owner

Once family members hold shares or work in the business, the year-end plan has to clear the tax on split income rules before any income moves to them. TOSI taxes dividends received by most family members at the top personal rate unless an exclusion applies. The main ones are working in the business on a regular basis, roughly an average of 20 hours a week in the current year or in any five earlier years, or being 25 or older and holding shares that meet the excluded-share tests. These are fact tests, and the facts have to exist before December, not be written up in April.

Salary to a spouse or adult child stands on different ground: it must be reasonable for work actually performed, at a rate you would pay an unrelated employee for the same job. Where it is, it deducts against corporate income and builds that family member's own RRSP room and CPP record, which is often worth more over time than the current-year rate difference.

The personal side of the ledger deserves the same attention as the corporate side. One large December dividend can land in a higher bracket than two moderate ones straddling December and January. A big dividend year triggers instalments the following year, so part of the cash should be parked for tax rather than spent. RRSP contributions can wait for the first 60 days of the new year, but a charitable donation you want credited this year cannot pass December 31.

Year-end leverWhat it doesThe timing that matters
Accrued bonusDeducts against corporate income this yearMust be paid within 180 days of year-end, with source deductions remitted
Salary through payrollCorporate deduction, RRSP room, CPP recordProcessed and withheld before December 31 to count this year
Taxable dividendDistributes after-tax profit; releases RDTOH refundsDirectors' resolution when paid; T5 filed by end of February
Capital dividendPays out the capital dividend account tax-freeElection filed on or before the day the dividend becomes payable
Shareholder loan repaymentAvoids a full personal income inclusionWithin one year after the end of the corporate year of the draw
RRSP contributionPersonal deduction against salaryFirst 60 days of the new year for the prior tax year

The facts that change the mix, and how we plan it

Six facts decide the right year-end mix, and all six are knowable in November:

  • Corporate income against the $500,000 limit. Sets whether bonusing down, retaining at the general rate, or building GRIP is even on the table.
  • Your personal cash need. The plan has to fund your life first; tax planning optimizes around that number, never instead of it.
  • RRSP room and CPP goals. Salary is the only route to both, and their value depends on your age and time horizon.
  • The shareholder loan balance. An outstanding balance forces part of the answer no matter what you would prefer.
  • Passive income and RDTOH. Investment income can grind the small business limit while the corporation sits on refunds that only dividends release.
  • Family shareholders. TOSI and reasonableness decide whether any income can move across the household at all.

Sequencing matters as much as the answer, because half of these levers close at year-end. A dividend can be declared in the new year; the bonus accrual, the payroll run, the donation and the loan repayment cannot be backdated to it.

We run this as a standing fall exercise inside corporate tax planning for owner-managed businesses: the pools reconciled, the scenarios modelled at real rates, and the resolutions and payroll entries completed before December 31 instead of reconstructed in April. Tax Planning & Advisory starts with a free 15-minute discovery call, and you get the scope and fee in writing before any work begins.

Common questions

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Should I pay myself salary or dividends this year?

It depends on your cash need, whether you want RRSP room and CPP, where corporate income sits against the $500,000 limit, and what is in the RDTOH and GRIP pools. Most owners land on a blend, recalculated each year rather than repeated.

What happens if my shareholder loan is still outstanding at year-end?

You have until one year after the end of the corporation's taxation year in which you drew the money to repay it or convert it to salary or a dividend. After that the full balance is added to your personal income with no corporate deduction, and an interest benefit applies in the meantime.

When should year-end compensation planning actually happen?

Two to three months before the corporate year-end, while bonuses, payroll, donations and loan repayments can still be executed inside the year. A corporate tax planning CPA in Ontario should be modelling this in the fall, not classifying draws after the fact in April.

Keep reading

03

Corporate tax planning

The year-round plan that year-end compensation slots into.

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The small business deduction

Why the first $500,000 is taxed at 12.2%, and what grinds it away.

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Tax Planning & Advisory

Year-end modelling done before December 31, not after.

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