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Taxation of Foreign Income in a Corporate Account

August 2, 2016 - 6 comments

Dan Bortolotti’s recent blog post raised a number of questions from his readers concerning the impact of foreign withholding taxes within a corporate account. This is a hot topic, as many successful professionals are choosing to save within their corporation. Couch Potato investors often allocate 40% or more to foreign stocks, so it’s important for them to grasp these tax concepts before implementing their own portfolio.

Foreign interest income vs. foreign dividend income

The taxation of foreign income is often lumped into the “interest income” category, but this is not entirely accurate.  Foreign interest income (the kind that is generally not subject to foreign withholding taxes) is taxed in a similar manner to Canadian interest income in a corporation. So holding a tax-efficient global bond fund in your corporate account should be just fine. 

Foreign dividend income, on the other hand, can affect the amount of corporate taxes that are refundable when dividends are paid to you as a shareholder. For Couch potato investors, this foreign dividend income is typically received on a quarterly basis from your US, international and emerging markets equity ETFs. Foreign dividends are not specifically the issue – it is technically the foreign non-business income tax credit that throws a wrench into the refundable tax calculation.

In order to better understand the taxation of foreign dividend income in a corporation, we’ll start with the calculation of Part I tax, and move to the calculation of the refundable portion of Part I tax. We’ll then follow the dividend income out of the corporation and into the personal hands of the shareholder in order to calculate the overall taxes paid. To make the math easier, we’ll use $10,000 as our foreign dividend income figure, and assume a 15% withholding tax rate on the income (or $1,500).

Part I tax calculation

Similar to the corporate taxation of interest income, there is a base federal tax amount of 38%, along with an additional refundable tax of 6.67% (this has been increased to 10.67% in 2016). A federal tax reduction of 10% is then applied, and the foreign non-business income taxes paid are offset by the foreign non-business income tax credit of 15%. This results in Part I tax payable of 19.67% (38% + 6.67% - 10% - 15%).

Once we include provincial tax of 11.5% (for an Ontario corporation), our total taxes payable increase to 31.17% (19.67% + 11.5%). As we had initially paid 15% foreign withholding tax on the dividend income, this amount should also be included in order to calculate our total taxes. This equals 46.17% (31.17% + 15%), which is the combined federal/provincial tax rate for passive investment income earned within an Ontario corporation in 2015 (this amount is increasing to 50.17% in 2016).

Part I Tax Calculation

Source: CCH Corporate TaxPrep Software

Source: CCH Corporate TaxPrep Software

Refundable portion of Part I tax

A portion of Part I taxes are refundable when dividends are ultimately paid out of the corporation to the shareholder. For interest income, the refundable amount is 26.67% (increasing to 30.67% in 2016). In our example below, the tax refund is only 15.24% of the dividend income. As mentioned earlier, this difference is due to the foreign non-business income tax credit. The refundable amount of tax would change depending on the withholding tax rate levied on the foreign dividends (for example, if you held an international equity ETF that withheld 12% instead of 15%, the refundable amount would differ).

Refundable portion of Part I tax calculation

Source: CCH Corporate TaxPrep Software

Personal Tax Calculation

Of the $4,617 of total taxes paid on our $10,000 of foreign dividend income, $3,093 is non-refundable, and $1,524 is refundable when sufficient dividends are paid out to the shareholder. Since the after-tax corporate income is $5,383 ($10,000 - $3,093 - $1,524), there is currently $6,907 available to distribute to the shareholder ($5,383 after-tax corporate income + $1,524 refundable taxes).

If we assume that the distribution is in the form of a non-eligible dividend paid to an Ontario resident in the highest tax bracket, their personal taxes would be $2,772 in 2015 ($6,907 non-eligible dividend × 40.13% tax on non-eligible dividends). This would leave them with $4,135 of after-tax income ($6,907 - $2,772). I’ve illustrated the concepts in the chart below (adapted from Jamie Golombek’s 2014 article).

Foreign dividend income earned in a corporation in Ontario in 2015

Sources: Adapted from In Good Company: Retaining investment income in your corporation, Deloitte 2015 Top marginal income tax rates for individuals

The overall taxes paid on the $10,000 of foreign dividend income was $5,865 ($3,093 non-refundable corporate tax + $2,772 personal tax) or 58.65%, which is 9.12% higher than the top 49.53% tax rate in 2015 which would apply for an Ontario resident that earned the foreign dividend income personally.

This would suggest that an investor may be better off investing in foreign equities outside of their corporate account (i.e. in personal non-registered accounts, RRSPs, TFSAs, etc.). For investors who are comfortable with swap-based ETFs (such the Horizons S&P 500 Index ETF (HXS)), this may also be a suitable option, as the fund does not distribute foreign dividend income, and will therefore avoid foreign withholding taxes and the offsetting credit.

By: Justin Bender with 6 comments.
  06/07/2017 3:22:36 PM
Justin Bender
@VIK: I would recommend speaking with an accountant for your specific corporate tax preparation questions.
  30/06/2017 4:37:13 PM
I have CCPC which trades and holds stocks. So it generates capital gains and dividend income from these sources. This is sole income of the company. The Capital gains and dividends are rec'd in CDN and US dollars. I use Canadian trading platform to conduct the buying and selling. Holding and selling these investments is the nature of the business and are not savings that invested for the corporation. How do I report them on the corporate return T2. Thanks
  22/02/2017 11:39:28 AM
Justin Bender
@Phil: Unfortunately there's no magic calculator ;) In this case, it would be best to speak with your accountant.
  20/02/2017 7:46:38 PM
So I know there's no white paper yet but I'm back at the numbers and I'm trying to figure out: below what personal tax rate ( AB) does it make sense to to withdraw funds from a corp in the form of non eligible dividends to invest in a non registered taxable account with XEF or VUN if tax rates were to become lower in retirement. I've noticed it gets more complicated when over 10 year term and including cap gains and the fact that there is more upfront investment in the corp. Do you have a magic calculator:-) ?
  02/12/2016 10:42:30 AM
Justin Bender
@Phil: Glad you liked the blog post and Dan's new podcast!

I will likely put together a white paper over the next year that will touch on many of your requested corporate taxation questions (so keep your eyes peeled for it).
  02/12/2016 12:32:30 AM
Great blog post, also I liked your first pod cast. Nice to get some behind the scenes perspective.

As for the corporate investment acct could you provide the final total rates for other types of investment income or perhaps what would result with the use of common etfs eg cdn or international dividends, interest, discount cdn bond funds, swap structures

Thanks for your consideration, I feel like a kid playing a new video game while planning long term projections:-)

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