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How Incorporated Doctors, Dentists, and Lawyers Can Cut Their Tax Bill in Half

Feb 01, 2025

The Professional Corporation: A Tool That Is Being Underused

Incorporation is nearly universal among high-income Canadian professionals. Doctors, dentists, lawyers, engineers, and other regulated professionals incorporate their practices primarily for one reason: the small business deduction. By operating through a Canadian Controlled Private Corporation, the first $500,000 of active professional income is taxed at approximately 9% in most provinces — rather than the personal marginal rate that can exceed 53%. The tax saving in the first year of incorporation alone is often in the tens of thousands of dollars.

The problem is that most incorporated professionals stop there. They incorporate, they pay themselves through a combination of salary and dividends, they accumulate retained earnings in the corporate account, and they assume the structure is working as intended. It is — but only partially. The professional corporation, as most practitioners use it, captures only the first layer of structural advantage. The deeper layers remain untouched.

Most incorporated professionals capture the small business deduction on active income and stop there. The deeper structural advantages — passive income optimization, internal financing, CDA credit — remain entirely unused.

The Retained Earnings Problem for Professional Corporations

Professional corporations are exceptional at generating retained earnings. A busy dentist or specialist physician may accumulate $150,000 to $300,000 in annual corporate surplus after their personal draws. Over a 10-year career, this can represent $1 million to $3 million sitting inside the professional corporation — exposed to passive income tax, generating minimal growth, and creating a growing tax liability at every decision point.

The passive income tax problem is particularly acute for professionals because of the small business deduction clawback. Recall that when a CCPC generates more than $50,000 in passive income in a year, the small business rate on active income begins to erode. For a professional corporation with $1 million in retained earnings generating a conservative 5% return, that is $50,000 in passive income — exactly at the clawback threshold. Another year of accumulation and the SBD itself is at risk.

How Capital Architecture Solves the Professional Corporation Problem

The InfiniCap System™ addresses the professional corporation's structural inefficiency at every layer. By redirecting retained earnings from a taxable corporate investment account into a corporate-owned participating whole life policy, the capital moves out of the passive income environment entirely. Growth inside the policy is tax-deferred and does not count as passive income for the SBD clawback calculation. The professional corporation can accumulate millions in structured capital without eroding the small business rate on active professional income.

The professional can access that capital through policy loans — tax-free, at any time, for any purpose — while the internal growth continues uninterrupted. They can fund a real estate acquisition, a practice expansion, a sabbatical, or early retirement planning, all without triggering a taxable event at the point of access. And when they eventually wind down the corporation, the CDA credit generated by the policy provides a tax-free extraction mechanism for the residual corporate capital.

For an incorporated professional generating $200,000 in annual retained earnings, the InfiniCap System™ can preserve the full small business deduction, eliminate passive income tax on growth, and create tax-free access to capital — simultaneously.

The Professional Who Acts Early Compounds the Advantage

Capital architecture is a time-sensitive advantage. Every year that retained earnings accumulate in a taxable corporate account is a year of compounding that is lost to passive income tax and SBD erosion. A professional who implements the architecture at age 38 versus age 52 does not just enjoy 14 additional years of growth — they enjoy 14 additional years of tax-deferred compounding on an exponentially larger base. The structural advantage compounds, just as the capital does.

For incorporated professionals, the conversation is not whether to implement a capital architecture framework. The question is how much additional tax has already been paid by not implementing it sooner — and how quickly the structure can begin recovering that ground.