21 January 2009 External T.I. 2008-0266191E5 F - Part IV & Capital Gain Strip -- summary under Paragraph 186(1)(b)

CRA confirmed its position in 9711005 and indicated that its position in 9906255 was no longer valid because of the 943963 Ontario decision. Accordingly, the portion of the dividend representing safe income on hand was subject to Part IV tax and the Part IV tax applied irrespective of a portion of the dividend being deemed not to be a dividend received by virtue of s. 55(2)(a).