When asked for an overview of the distinctions between ss. 112(3.2)(a)(ii)(A), (B) and (C), the Directorate stated:
[F]or the purposes of clause 112(3.2)(a)(ii)(A), only taxable dividends that are not designated and that are taxed in the trust are subject to clause 112(3.2)(a)(ii)(A). Taxable dividends that are designated by the trust under subsection 104(19) to a beneficiary who is an individual are subject to clause 112(3.2)(a)(ii)(B). Finally, taxable dividends designated by the trust under subsection 104(19) to a beneficiary that is a corporation, partnership or other trust are subject to clause 112(3.2)(a)(ii)(C) to the extent that the holding-period conditions referred to therein are satisfied.