Section 121

Cases

Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

A s. 15(1) benefit is not eligible for the dividend tax credit.

Administrative Policy

4 October 2012 External T.I. 2012-0439041E5 - Dividend Tax Credit

In response to a question as to whether "a taxpayer has the discretion to claim only a portion of the DTC [dividend tax credit] available in determining his or her total taxes payable for the tax year," CRA indicated that

Because section 121 of the Act specifies that a taxpayer may deduct "the total of" the amounts, if any, computed under paragraphs (a) and (b), it is our view that an individual may either claim the entire DTC available or not claim the DTC at all.

26 November 1990 Memorandum (Tax Window, Prelim. No. 2, p. 11, ΒΆ1045)

A trust is entitled to the dividend tax credit on dividends received from taxable Canadian corporations and either paid or payable to beneficiaries, where a designation is not made under s. 104(19).

Articles

Don Nilson, "Tax Smart Investing", CCH Tax Topics, No. 1903, p. 1, 28 August 2008: includes discussion of history of dividend tax credit.