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You say that the management company in a three tier real estate investment structure only pays %15.5 tax on its business profits. But would this not only be the case if this management company employees 5 or more people? If less then five people what rate would the company pay on its profits.
The property management company in the 3-tier structure will pay corporate income tax at the small business rate of 13.5% (Federal + Ontario). The property management company does not have to have more than 5 full time employees in order to take advantage of the small business tax rate. Note that the investment corporation, which owns the rental properties, pays corporate income tax at a rate of 50% (Federal + Ontario).