Principal Issues: A corporation (Aco) owns 40% of the shares of the capital stock of another corporation (Bco). Aco is a CCPC. Aco receives a dividend from Bco on January 10, 2001. On January 26, 2001, all of the shares of the capital stock of Bco are acquired by a non-resident. Bco's full rate taxable income for its taxation year beginning on January 1, 2001 and ending on January 25, 2001 is nil. In determining the amount to be included in the GRIP addition for 2006 of Aco, whether the dividend paid by Bco would be described in paragraph (c) of variable A in subsection 89(7).
Position Adoptée: No.
Raisons: It is not reasonable to consider, having regard to all the circumstances, that the dividend was attributable to an amount that is described in paragraph (a), (b) or (c) of variable A in subsection 89(7) in respect of Bco.