The U.S. (s. 871(m)) characterization, as a dividend, of a principal or derivative payment by a Canadian issuer to a Canadian investor, is irrelevant to T5 reporting

CRA has confirmed that the fact that payments made under a note or derivative by a Canadian issuer to a Canadian investor are treated under Code s. 871(m) as dividend equivalent payments that are subject to U.S. withholding tax should not affect how the same payments are characterized for purposes of T5 reporting by the Canadian issuer.

Neal Armstrong. Summary of 24 October 2017 External T.I. 2016-0653441E5 under Reg. 201(1)(a).