CRA specifies the notification requirements for a PUC grind under the foreign affiliate dumping rules
24 June 2015 - 8:36am
212.3(7)(d) provides that if a CRIC does not file "in prescribed manner a form containing prescribed information" by its filing-due date, amounts which otherwise would have ground the paid-up capital of shares of the CRIC or a qualifying substitute corporation, will be deemed to be paid as a dividend, thereby attracting Part XIII tax. No Regulation has been drafted.
CRA will treat this filing requirement as being satisfied by a letter containing particulars specified by it, including some informational particulars not specifically mentioned in s. 212.3(7)(d)(i).
Neal Armstrong. Summary of 12 June 2015 T.I. 2015-0583821E5 under s. 212.3(7).