Where s. 55(2) applies to a dividend that is not received on a redemption, acquisition or cancellation of a share to which s. 84(2) or (3) applies, the dividend recipient is deemed to have a gain under s. 55(2)(c) for the year in which the dividend was received from the disposition of the property. In 2011-0412131C6, CRA indicated that the resulting capital dividend account addition caused by the application of former s. 55(2)(c) is only available for distribution in the following taxation year.
Does the deemed gain and resulting CDA addition occur at the time of the dividend payment?
CRA responded that in light of the amended s. 55(2)(c) wording and its understanding of the tax policy of s. 55(2), the amount deemed to be a gain under s. 55(2)(c) is deemed to be realized on the disposition of a capital property at the time of the payment of the dividend – for purposes of inclusion in income, but also for the purpose of the CDA definition.