I think perhaps Tim Cestnik could offer some clarification. As far as I can determine the Ontario rate for corporate investment income (prov and fed combined) is 50.17% for CCPCs. This is not much different from the 53% top marginal rate and the corporate rate pertains on the first dollar of investment income. I am not sure I see much difference between the 2 rates. Certainly it is not true that investment income in a CCPC benefits from the 15% rate for Part I (operating income)