CRA finds that a s. 84.1 deemed dividend can be an eligible dividend

CRA accepts that a dividend which is deemed by s. 84.1 to be received by an individual from a corporation with which he does not deal at arm's length is an eligible dividend which the deemed payor of the dividend can designate under s. 89(1) as coming out of its GRIP notwithstanding that the individual does not hold any shares of that corporation.

Neal Armstrong.  Summary of 5 October 2012 APFF Roundtable, Q. 11 2012-0454091C6 F under s. 89(14).