In response to a query as to whether the adjusted aggregate investment income (“AAII”) of a corporation for a taxation year, which is relevant for purposes of calculating its business limit reduction under s. 125(5.1)(b) (“BL Reduction”), can be a negative amount, CRA stated:
Aggregate Investment Income (“AII”) which is defined in subsection 129(4) of the Act, is the basis for the determination of a taxpayer’s AAII for the year and generally includes only two categories of income; the eligible portion of a corporation’s net taxable capital gains and the corporation’s income for the year from a source that is property, subject to certain exclusions, in excess of a corporation’s loss for the year from a source that is a property. Only the excess amount of a corporation’s taxable capital gains and income from a source that is property are required to be included in the AII computation for a particular taxation year. Thus, there are no circumstances in which the calculation of a taxpayer’s AII can result in a negative amount.