CRA continues to be prepared to issue rulings dealing with the s. 55(2.1)(b) purpose tests

When asked to provide any update on the application of s. 55(2) to ordinary course intra-group dividends, CRA indicated:

• Consistent with its prior statements, CRA continues to be open to considering a ruling request involving the determination of the purpose where all manifestations of purpose in the circumstances supported the absence of the purposes described in s. 55(2.1)(b) and the taxpayer represents that there is no such purpose.
• Where a taxpayer request relates to safe income (so that reliance is not being placed on the s. 55(2.1)(b) purpose tests), taxpayers have needed to manage the safe income determination time notion (of a series with respect to the safe income exception in 55(2.1)(c).)

Neal Armstrong. Summary of 3 December 2024 CTF Roundtable, Q.2 under s. 55(2.1)(b).