4 January 2012 External T.I. 2011-0414731E5 F - Interaction between 84.1 and 83(2) ITA -- summary under Subsection 83(2)

CRA does not plan to adopt an administrative position which would allow a private corporation to make a s. 83(2) election with respect to a dividend deemed to be paid by it under s. 84.1(1)(b) to a person who is not already a shareholder of the corporation.