The carrier phase of cellular signals can be utilized for highly accurate positioning, with the potential for orders-of-magnitude performance improvements compared to standard time-difference-of-arrival positioning. Due to the integer ambiguities, standard performance evaluation tools such as the Cramér-Rao bound (CRB) are overly optimistic. In this paper, a new performance bound, called the mixed-integer CRB (MICRB) is introduced that explicitly accounts for this integer ambiguity. While computationally more complex than the standard CRB, the MICRB can accurately predict positioning performance, as verified by numerical simulations, and hence it serves as a useful guide to choose the system parameters that facilitate carrier phase positioning.