Subco earned $160,000 of full rate taxable income in each of the 2001 to 2005 years and paid to its wholly-owning parent (Parentco) in each of those years a taxable dividend of $110,000, In confirming that Parentco's and Subco's GRIP addition, pursuant to subsection 89(7), would be $504 000 and $0, respectively, CRA indicated in its summary that:
It would be reasonable to consider that $504 000 of the total dividends of $550 000 that Parentco received from Subco during the relevant period was attributable to an amount described in variable A of the formula in respect of Subco's GRIP Addition under subsection 89(7).