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The Queen, 2022 TCC 68, rev'd 2024 FCA 42-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) circular use of capital dividends abused the purpose of the CDA Following preliminary transactions, on June 28, 2004, a Canadian holding company (“Micsau”) held all the shares, having a fair market value (“FMV”) and adjusted cost base (“ACB”) of $101.8M and $48.1M respectively, and a nominal paid-up capital (“PUC”), of a holding company (“3295940”), which held a minority shareholding (having an FMV of $88.5M and an ACB of $4M, reflecting the crystallization of the safe income on hand of such shares, and a nominal PUC) in another holding company (“Holdings” – which was majority-owned by an non-resident arm’s length investor), which carried on a Canadian generic-pharmaceuticals business. ...