In the absence of the Part I refundable tax, the total personal and corporate taxes on investment income earned by, and flowed through, a CCPC could approach an unreasonably high 70 percent. While the Part I refundable tax reduces this combined rate to a more reasonable level, the same result could have been achieved by lowering the tax rate applicable to the investment income of a CCPC. Why did the government not adopt this less complex alternative?
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