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By Hayley Brown, CPA, CA, senior manager, tax services, KPMG LLP, and Shane Onufrechuk, FCPA, FCA, partner, tax services, KPMG LLP, chair of CPABC Taxation Forum, chair of CPABC Professional Development Tax Advisory Group.
The new subsection 55(2) of the Income Tax Act was released by Canada's Department of Finance in 2015 and enacted into law in 2016. Specific examples of common situations in which the recipients of inter-corporate dividends should consider the potential application of subsection 55(2). Identify ways to avoid the application of subsection 55(2). Creditor-proofing dividends. Dividends paid on discretionary dividend shares. Non-participating shares. Participating shares.