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24 November 2015 Annual CTF Roundtable - Official Response
Miscellaneous correspondence
In our view, the court’s objective was to achieve a balance between fostering compliance in the context of Canada’s self-assessment system (the denial of the dividend refund) and continuing respect of the integration principle (the non-reduction of the RDTOH balance). ... For example, assume that a corporation has issued shares that are non-participating and non-voting but do allow for discretionary dividends. ... The CRA view is that for the purpose of the METC, medical services are diagnostic, therapeutic or rehabilitative services that are performed by a medical practitioner acting within the scope of his or her professional training. ...