CRA treats post-redemption payments to a contributing taxpayer as a dividend at the time

Several years after the redemption of preferred shares which the taxpayer had received for the transfer under s. 85(1) of property to Opco, CRA determines that the transfer had occurred at an under-valuation, so that the taxpayer receives an additional payment from Opco "pursuant to" the price adjustment clause in the redeemed shares.  CRA considers that this payment will be recognized by the taxpayer as a dividend in the year of payment.

In many situations, the taxpayer would be better off not implementing such a price adjustment clause.

Neal Armstrong.  Summary of 29 October 2013 T.I. 2013-0507881E5 ("Price adjustment clause") under s. 84(3).