Can a private corporation, at the time of filing its T2 return, choose to not apply for a dividend refund ("DR")? CRA responded that although it is not mandatory to apply for any available refund, CRA under s. 129(1)(a) has the discretion to refund the DR without a request therefor, so that CRA “is not obliged to accede to the request of the private corporation” to not receive the DR. CRA further stated:
Currently, the CRA policy… is to automatically make a DR where the information required for the calculation of the DR has been filed on the T2 return (including the Schedule 3/T2SCH3), even where a private corporation does not request it (for example, by entering zero on line 784 of his T2 return).