26 January 2023 External T.I. 2021-0887661E5 - Small Business Deduction - Related -- summary under Clause 125(1)(a)(i)(B)

CRA indicated that where two CCPCs, wholly-owned by Mr. or Mrs. X, did not provide services or property, directly or indirectly, in any manner whatever, to the other, then on that basis neither CCPC would be considered to have earned income described in s. (a)(i) of the definition of “specified corporate income” in s. 125(7), i.e., s. 125(1)(a)(i)(B) would not carve out any such income from that income eligible for the small business deduction.