Subsection 55(2)

payment of non-eligible dividend by an Opco with both NERDTOH and ERDTOH to Holdco avoids s. 55(2) if the resulting s. 186(1)(b) tax is not refunded as part of the same series

Pt. IV and safe income exclusions under s. 55(2) can be doubled up

application of s. 55(2) does not affect amount of assessable dividend for Pt. IV tax purposes

s. 55(2) operated through denying a s. 53(1)(b) ACB bump

s. 40(1)(a)(iii) reserve available where redemption proceeds payable on earnout basis

relationship between Part IV tax and s. 55(2) and related amended return filings

where Holdco receives a dividend subject to refundable Pt IV tax and to s. 55(2), two different dividends should be reported for Pt IV and s. 55(2) purposes

repeal of the s. 55(2) exemption, for dividends for which the Part IV tax is refunded on on-payment to an individual shareholder, busts integration