Must a corporation add a s. 110.5 addition to its taxable income in computing its safe income? After stating that
...income "earned or realized," to which subsection 55(2) refers, is the net income, as computed in Division B of Part I.
whereas “section 110.5 provides for an addition to taxable income,” CRA stated:
Consequently, taking into account our interpretation of the word "income" as a starting point for paragraphs 55(5)(b) to (d), that amount would not be included. Paragraphs 55(5)(b) to (d) do not contain any adjustment that would add the amount of taxable income added under section 110.5 to the safe income calculation. Consequently, that amount would not be part of the safe income or "income earned or realized" under those provisions.