Principal Issues: In a given situation where, in a particular taxation year, Bco receives from its wholly-owned subsidiary (Aco) two taxable dividends (the first, an eligible dividend of $3.5 million and a second of $1.5 million), the two taxable dividends are subject to the application of subsection 55(2), and, Bco has designated the first taxable dividend to be two separate taxable dividends of $3 million (the amount of the safe income on hand attributable to the gain on its shares) and another of $500,000, pursuant to paragraph 55(5)(f), whether Bco could include the first taxable dividend in computing its GRIP even though the said taxable dividend is subject to paragraph 55(2)(a)?
Position: No. Bco could include in its GRIP only $3 million.
Reasons: Previous position reiterated.