Holdco 2 wholly-owns Opco 2. A(a) and (b) of s. 89(7) for Opco 2 are nil for the taxation year ending in 2001, while they aggregate $100,000 for each of the taxation years ending in 2002 to 2005, inclusive. The only dividend paid by Opco 2 in its 2001 to 2005 taxation years was a $400,000 taxable dividend of $400,000 during the Period. Opco 1 would have paid that dividend in 2005, while Opco 2 would have paid such a dividend in 2001.
CRA indicated that in determining the amount to be included in the GRIP addition for 2006 of the recipient corporation (Holdco 2) in respect of a dividend received during a taxation year ended after 2000 and before 2006 (the $400,000 dividend paid in 2001), one may consider the total amounts of full rate taxable income of the payer corporation (Opco 2) for its 2001 to 2005 taxation years.