Principal Issues: 1. Whether the TOSI rules will apply to a deemed dividend received by individuals on the redemption of their common shares in an investment holding company. 2. Whether TOSI will apply to a deemed dividend received by an estate and allocated to the beneficiaries.
Position: 1. Depends on the particular facts, but in this case probably not. 2. Depends on the particular facts.
Reasons: Meets technical requirements.