10 February 2011 External T.I. 2010-0387151E5 - Deemed Disposition of Shares by a Non-Resident -- summary under Subsection 116(5)

On the redemption of shares of a non-resident which are taxable Canadian property, any resulting deemed dividend that is subject to Part XIII tax under s. 212(2) will not reduce the amount of withholding required under s. 116(5) where no s. 116 certificate is obtained.