Section 185.1

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...

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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...

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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...

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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...

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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...

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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