CRA may be amenable to late eligible dividend designations where GRIP arises on audit

If a CCPC were determined on audit to have been carrying on a personal services business, so that it was assessed to deny the small business deduction and retroactively acquired a "GRIP," CRA typically would be amenable to a late eligible dividend designation respecting dividends that would have gone out of such high-rate income pool, provided that the taxpayer had been careful in its reporting position that it had been eligible for the small business deduction.

Neal Armstrong.  Summary of 11 October 2013 APFF Roundtable Q.14, 2013-0495771C6 F under s. 89(14.1).