AAII integration anomaly

In November, Ontario announced it would not implement the AAII clawback for the small business deduction (SBD). This creates an integration anomaly. If the federal clawback applies, the related income will be part of GRIP for federal and Ontario purposes even though the Ontario SBD might have applied to that income. The result is that income that has been subject to tax in Ontario at its small business rate could end up being paid out as eligible dividends. Jamie Golombek and Jay Goodis, “Ontario Announcement Throws a Wrench into Integration” 27:1 Canadian Tax Highlights (January 2019).