The definition of “adjusted aggregate investment income” (whose amount can grind the business limit) excludes capital gains from “active assets” including qualifying shares. Where s. 55(2)(b) or (c) deems a dividend to be a capital gain, it does not go on to deem it to be a gain from the disposition of an active asset even where the dividend or deemed dividend in question arose on such an “active” share.
CRA confirmed that, notwithstanding this gap of sorts, it will consider the s. 55(2) gain to be from an active asset if indeed, the shares in question were active assets.