Possible need for a specific anti-avoidance purpose (p. 6-5)
[C]ertain practitioners have suggested that in the absence of a specific...
Targeted mischief of scaling back Pt IV tax refund (p. 6:10)
[T]he part IV tax exception no longer applies when, as part of a series of...
Failure of s. 55(2.3) to explicitly split the deemed dividend into 2 separate dividends (p. 6:12)
[P]aragraph 55(2.3)(a) deems the amount as...
Risk of CRA calculating safe income where taxpayer has applied s. 55(2) (pp. 6:13-14)
If a taxpayer has not calculated its safe income on hand and...
Annual cash dividends generally not a series (p. 6:17)
One issue to consider is whether annual dividends may be part of the same series of...
Avoidance of exclusion if Pt. IV refund not received as part of the series (pp. 6:27-29)
[A]ny dividend paid from Holdco to the shareholder needs...
Avoidance of s. 55(2) through accessing related party exemption (p. 6:31)
[O]ne strategy to avoid subsection 55(2) is to restructure a dividend...
PUC-streaming under s. 84(1)(c) (pp. 6:45-46)
…CRA has not made any specific comments regarding the potential application of new section 55 to...