CRA indicates that it has not been deluged by ruling requests on the s. 55(2.1)(b) purpose test
CRA repeated an earlier statement that it can provide rulings on the application of the purpose test in s. 55(2.1)(b) provided that “all manifestations of purpose and corroborating circumstances support the absence of one of the purposes described in paragraph 55(2.1)(b)” and the taxpayer represents “that the purposes for which the dividend was paid do not include one of [such] purposes.” CRA unsurprisingly indicated that it “other than rulings on loss-consolidation, the CRA has not been deluged by requests for rulings on this topic.”
The “Manual used … [in] audits of small and medium-sized businesses does not contain any information on the application of subsection 55(2) and the purpose test, in particular.”
Neal Armstrong. Summary of 9 May 2018 CPA Roundtable Q. 11, 2018-0765271C6 under s. 55(2.1)(b).