7 October 2021 APFF Roundtable Q. 9, 2021-0901101C6 F - Part IV tax exception vs eligible and non-eligible -- attach -- Subsection 55(2)

payment of non-eligible dividend by an Opco with both NERDTOH and ERDTOH to Holdco avoids s. 55(2) if the resulting s. 186(1)(b) tax is not refunded as part of the same series