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The amount of interest on the "overpayment" would be calculated at the prescribed rate … for the period from the latest of the days referred to in paragraphs 164(3)(a) to (e), taking into account paragraph 164(5)(d), to the day on which the amount is refunded or applied. ...

(a)(i)(B)(I) of that definition indicates that such income is excluded from being specified corporate income for such SBD purposes if “it is not the case that all or substantially all of [Opco B]’s income for the year from an active business is from the provision of services or property to … persons (other than the private corporation) with which [Opco B] deals at arm's length.” ...

Accordingly, the dividends received by the Newco and Opco will not be subject to subsection 55(2) because A will be related to B pursuant to paragraph 251(2)(a) …. ...

In the 2020 Loss Year, Opco paid two taxable dividends of $200 each to its corporate shareholder, which it designated as eligible dividends – and then made an excessive eligible dividend designation in respect of each dividend. ...

. … [and] that a legal obligation to pay under contract does not exist until all contractual preconditions to which the payment relates are fulfilled [citing Wawang Forest Products]. ...

. … Therefore…paragraph 248(28)(a)… applies to remedy the situation and avoid double taxation of the same amount. ...

Would Opco and Newco be associated under ss. 256(1.2)(f)(ii) and 256(1.3) – and would it make any difference if the trust deed precluded only the distribution of income before 18? ...

. … If corporate income has not previously been taxed, whether because the corporation was entitled to certain tax benefits under the Act or for any other reason, then a dividend paid by the corporation from such income should be subject to subsection 55(2) unless none of the purposes of the dividend is described in proposed paragraph 55(2.1)(b). ...

X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...

X, CRA indicated that Amalco shares that were substituted for his Holdco common shares had not been held by anyone other than him, and that, prior to being replaced by Holdco shares, the original Opco share had not been owned by anyone other than him – and in this regard, stated that s. “110.6(1)(e) can apply respecting multiple substitutions.” ...