After finding that s. 55(2) would apply to the deemed dividend arising on the redemption of preferred shares of a CCPC held by an unrelated public corporation, CRA stated:
[A] taxable Canadian corporation is liable for Part VI.1 tax in respect of the portion of dividends, other than "excluded dividends", paid by it on short-term preferred shares or taxable preferred shares that exceeds the dividend allowance applicable to that corporation for the year. Since subsection 55(2) does not affect the dividend payer, the application of this statutory provision in a particular situation would not affect the amount of Part VI.1 tax payable by a particular corporation.