CRA will now only provide guidance on safe income allocation to discretionary dividend shares in ruling letters

We have now published the questions posed at the CRA Roundtable at the annual 2018 CTF Conference and our summaries of the oral responses of the Income Tax Rulings Directorate.

In response to Q.1 as to the allocation of safe income where a corporation has discretionary dividend shares, CRA indicated that:

  • It stands by all positions on this matter that it has expressed since the 2015 CTF Annual Conference.
  • On a going-forward basis the CRA is willing to provide assurance on the tax treatment of the discretionary dividend shares, but only in the context of a ruling request – and thus will no longer express its views on this matter in Technical Interpretations or Roundtable responses.

Neal Armstrong. Summary of 27 November 2018 CTF Roundtable, Q.1 under s. 55(2.1)(c).