Subsection 185.1(2)
Administrative Policy
17 November 2022 External T.I. 2021-0919001E5 F - Eligible Dividends and Non-Capital Loss Carry-Back
Opco made an excessive eligible dividend designation in respect of two dividends of $200 each paid by it in its 2020 taxation year, due to a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - General Rate Income Pool - Element B | B of formula reduces GRIP by NCLs carried back | 167 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(i) | CRA discretion re accepting adjustment to losses carried back provided that the amendment request is made within the s. 152(4)(b)(i) period and loss year not statute-barred | 322 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(6) - Paragraph 152(6)(c) | s. 152(6)(c) permitted amending carryback request, if made within s. 152(6)(c) deadline and normal reassessment period, and implicitly authorized consequential Part III.1 reassessment | 278 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(3) | s. 152(3) (and, consequentially, s. 185.2(2)) requires filing of amended return to reflect missing excessive dividend | 173 |
7 October 2020 APFF Roundtable Q. 11, 2020-0852231C6 F - Designation under subsection 89(14)
At 2017-0709021C6 F, CRA accepted, in circumstances specific to a wind-up, that the amount of the dividend paid out of the CDA need not be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 89 - Subsection 89(14) | dividend designation cannot state it is the GRIP, if less | 188 |
9 October 2015 APFF Roundtable Q. 23, 2015-0598311C6 F - Excessive eligible dividend designation
As no Regulation has been promulgated specifying the "prescribed manner" for electing under s. 185.1(2) to convert an excessive capital dividend...
Paragraph 185.1(2)(a)
Administrative Policy
13 May 2016 External T.I. 2016-0626371E5 - Subsection 185.1(2) election
During the year, Canco, a Canadian controlled private corporation, paid three separate dividends of $30,000 each to its three shareholders on...
Subsection 185.1(3)
Administrative Policy
7 October 2021 APFF Roundtable Q. 10, 2021-0901001C6 - Application of subsection 184(3) and 185.1(3)
Vendors may proceed with a preliminary reorganization before a share sale and agree in advance that elections will be made in the event of there...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) | CRA generally will accept the concurrence by a share vendor to an s. 184(3) election in advance of the excessive eligible dividend being identified | 243 |