28 August 2008 External T.I. 2008-0287611E5 F - Surplus Stripping -- summary under Subsection 84.1(1)

Regarding a proposed series of transactions whose purpose was to convert a taxable dividend that would otherwise have been paid by Opco into a proceeds of disposition to shareholders of Opco on the sale to a 3^rd party of freeze shares of Opco, CRA indicated that this was a dividend stripping arrangement to which all the conditions of either s. 84.1(1) or GAAR would apply.