9 October 2015 APFF Roundtable Q. 24, 2015-0598261C6 F - Calcul du revenu de placement total - annexe 7 -- summary under Aggregate Investment Income

Dividends which are deductible in the computation of taxable income are expressly excluded from "aggregate investment income," as defined in s. 129(4). Accordingly, where a Canadian-controlled private corporation incurs investment counselling fees for a portfolio which generates both dividends from Canadian corporations and interest income, it will be necessary to determine the portion of those fees which relate to the earning of the interest income as contrasted to the dividend income. Only the interest-related portion of the fees will reduce the CCPC’s aggregate investment income.