Where, in 2006, Bco's GRIP is $1.3 M and, pursuant to s. 84(3), Bco is deemed to have paid a dividend of approximately $1M to Cco and Dco (approximately $500,000 each), can Bco designate a fraction of the deemed dividend representing Bco's safe income on hand attributable to the purchased shares (approximately $700,000) as an eligible dividend, pursuant to s. 89(14)? CRA stated that:
[T]he CRA accepts, on an exceptional basis for 2006, that a corporation may designate as an "eligible dividend" pursuant to subsection 89(14) a fraction of a dividend where the dividend is declared on a class of shares of the capital stock of the corporation and paid to the holders of the shares of that class during 2006.