CRA accords a broad meaning to the concept in s. 84(2) of a distribution occurring "on" the reorganization or discontinuance of a "business"

S. 84(2) deems a Canadian-resident corporation to pay a dividend to the extent that a distribution made by it "on the winding-up, discontinuance or reorganization of its business" exceeds the related reduction, if any, in the paid-up capital of its shares.  In response to a question directed at a "pipeline strategy" (see 2011 STEPs Roundtable, Q. 5 2011-0401861C6), CRA noted that "business" for this purpose includes earning property income from investments, and that the broad meaning of the word "on" could include, for example, the situation where sales proceeds of a business are distributed some time after the sale.

Neal Armstrong.  Summary of  29 May 2012 CTF Prairie Tax Conference, Q. 14 2012-0445341C6 under s. 84(2).