GARRISONRisk and Capital

Corporate tax efficiency

Retained earnings, working instead of waiting.

Money left in a corporation is taxed three ways. Corporate-owned participating whole life turns that liability into an asset that grows tax-deferred, stays available to the business, and reaches your family without the tax bill.

Licensed across Canada. What to expect

A distribution yard at golden hour, trailers backed into the doors
How the strategy worksAn asset the three taxes can't touch

The corporation was the right place to earn it. Left there, it is taxed three times. There is one place inside it where none of that happens.

Active profit is taxed at 11.2% in Ontario. That part is fine. What it earns while it sits is taxed at about 50%, and past $50,000 of passive income a year the small business rate starts coming off, up to $30,000 a year in extra tax. When it finally comes out to you as a dividend, up to 47.74% goes again.

Corporate-owned participating whole life is a permanent policy the corporation owns, with a cash value that grows every year and a death benefit that is guaranteed. "Participating" means it shares in the earnings of the insurer's participating account, paid as an annual dividend. Once credited, a dividend is vested. It is never taken back.

  • Growth is tax-deferred

    Cash value grows inside an exempt policy with no annual tax. What the corporation would pay 50% on every year, it pays nothing on while it grows. The word that matters is exempt: a policy funded past the exempt test loses that status, which is why funding is designed, not maxed.

  • It is not passive income

    Growth inside the policy does not count toward the $50,000 line. It is the one place retained earnings compound without grinding the small business rate.

  • Corporate dollars, not personal

    Premiums come from income taxed at 11.2%, not 53.53%. A dollar of premium costs the corporation a fraction of what it would cost you personally.

  • The exit is tax-free

    At death the benefit is paid to the corporation. The amount above the policy's adjusted cost basis credits the capital dividend account and passes to your family as a tax-free capital dividend. The detail nobody mentions: the ACB declines as the policy ages, so the tax-free portion grows the longer it is held.

The participating whole life track recordDividends paid every year for more than a century

Participating whole life has paid a dividend every year, through everything, for more than a hundred years.

Participating whole life is the oldest form of permanent life insurance in Canada. The major participating accounts behind it have paid policyholder dividends every single year for over a century. That history, not a forecast, is what a corporation is holding when it owns one of these policies.

  1. 1914The First World WarPaid
  2. 1929The DepressionPaid
  3. 1939The Second World WarPaid
  4. 1981Interest rates at 21%Paid
  5. 2008The financial crisisPaid
  6. 2020The pandemicPaid
100+Years of participating whole life dividends paid, without missing one.
5–6%Dividend scale interest rates at the major participating accounts in recent years, on money that is not being taxed at 50% along the way.
  • A guaranteed floor

    Guaranteed cash values and a guaranteed death benefit. Dividends build on top of them, never underneath.

  • Smoothed, not swung

    The account holds government and corporate bonds, mortgages, real estate and equities, with returns smoothed over time. A bad year in the markets becomes a small adjustment to the dividend scale, not a loss on your statement.

  • Vested once paid

    Once a dividend is credited to the policy it is yours. It is never taken back.

Steady, compounding, tax-deferred, and not counted as passive income. That combination does not exist anywhere else in a corporation.

The immediate financing arrangementFor owners who need the capital in the business

Keep the capital working.

The IFA is how owners who can't afford to park capital get the policy anyway. The corporation buys the policy, borrows most of the cash value back from the bank the same year, and puts the money back to work. The policy keeps growing regardless.

The corporation buys the policy

A participating whole life policy, funded to build cash value quickly.

The bank lends against it

The policy is collaterally assigned and the corporation borrows back most of the cash surrender value, usually in the same year. That is the "immediate." Lenders that do this regularly advance close to the full cash value; the ones that don't, we don't use.

The capital goes back to work

Equipment, property, the business itself. Meanwhile the policy grows as if the money were still inside it. When the borrowed money earns business or investment income the loan interest is deductible, and the net cost of pure insurance is deductible too, because the policy is collateral for the loan. Both have conditions. We build the file so they are met.

IFAs suit corporations with strong cash flow and a banking relationship, typically from around $50,000 a year in premium. The review tells you whether yours is one of them.

The insured retirement planIncome later, without selling anything

The same policy, used the other way round: retirement income you never sell anything to get.

An IRP is not a different product. It is the whole life policy, funded during the years the business is strong, then used as the thing you borrow against when you want income and do not want to trigger tax. A loan is not income. It is repaid from the death benefit, and what is left still flows to your family through the capital dividend account.

That one fact is why it works. Almost everything the government takes from a retiree is triggered by income on a tax return: the tax itself, the Old Age Security clawback, the age credit. Money borrowed against a policy never appears there.

Build

The corporation funds the policy for a set number of years, designed to the exempt line with room to spare. Cash value compounds, untaxed, not counted as passive income.

Draw

When you want income, the policy is assigned as collateral and a lender advances against the cash value, year by year. No withdrawal, no disposition, no tax on the loan.

Settle

At death the benefit repays the loan. The balance is paid to the corporation and, through the CDA, to the people you built it for, tax-free.

Why the IRP worksIt touches nothing else you have

Every other source of retirement money is taxable when it arrives. This one is not.

A dividend, an RRSP withdrawal, CPP, OAS, a pension: stack them and the rate climbs, the clawback starts, the credits fall away. A loan against the policy sits outside that stack. Pick one to see what that means for it.

$80,000 in, $80,000 in hand

A loan is not taxable income, so an IRP draw adds nothing to your return. The same $80,000 taken as dividends from the corporation, at the top rate, leaves about $42,000.

Nothing on the return
Full OAS, kept

OAS is clawed back once net income passes roughly $93,000 and is gone entirely around $150,000. Borrowed money does not count toward that, so the OAS that dividends would have taken away stays yours.

No clawback
CPP, in a lower bracket

CPP is not means-tested, so nothing reduces it. What the IRP does is keep it from being piled under other income: CPP is taxed in a lower bracket because the draw is not stacked on top of it.

Untouched
RRIF at the minimum

RRIF minimums are mandatory from 71 and fully taxable. With an IRP beside them, the RRIF can be drawn at the minimum in a low bracket instead of being the only source and pushed up the scale.

Room untouched
Credits that stay

The federal age credit starts shrinking around $45,000 of income. Provincial credits and income-tested benefits follow the same return. None of them see a loan.

Income-tested, not loan-tested
Still compounding inside

Retirement money that would normally leave the corporation as a taxable dividend at up to 47.74% stays inside and keeps compounding, while a lender provides the cash flow against it.

No dividend needed
How we build it to holdFour checks, done before the first premium

An IRP is designed once and relied on for decades. Four things make it hold.

Each one is checked on paper before the policy is issued, so the plan you draw on at 65 is the plan you signed at 48.

  • Growth ahead of interest

    Loan interest usually accrues rather than being paid. We test the design at higher rates so the cash value stays comfortably ahead, and set the draw where it does.

  • Room inside the lender's limit

    Lenders advance a percentage of cash value. The draw is planned inside that limit with margin, so a softer dividend year changes nothing.

  • The right corporate structure

    Borrowed money reaches you from a corporately owned policy through one of a few recognized routes. We choose it with your accountant before issue.

  • Enough runway

    The policy is funded for ten to twenty years before it is drawn on, which is why it suits owners in their forties and fifties best. Started later, we build a different plan and say so.

Before anything is illustratedWhat we ask, and why

The design comes from your answers. These are the questions.

None of this is a sales script. It is the list we work through before a single number goes on paper, because a policy designed without these answers is designed for somebody else.

And when the honest answer is that this is not for you, that is what you will hear. Under $250,000 retained, a premium the business cannot carry in a bad year, or a need for the money back inside ten years: we say so, and tell you what to do instead.

  • What is the money for?

    Retirement income, a tax-free estate, collateral for the business, funding a buy-out. Each one is a different design.

  • When do you want to stop?

    The age you plan to step back sets the funding period and the year the draw can begin.

  • Who takes over?

    A child, a partner, a buyer, nobody. The exit decides whether the policy is built for the CDA, for a buy-sell, or for income.

  • What does a bad year look like?

    Your lowest cash flow in the last five years is the number the premium is sized to. Not the best one.

  • What else is already in place?

    Personal coverage, a holding company, an existing policy, a shareholders' agreement. We build around what exists rather than duplicating it.

Tax efficiency review1 of 5

What does the company do?

Closest fit.

How much is sitting in the corporation?

Retained earnings. Roughly is fine.

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Where is the company?

City or county in Ontario.

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