29 January 1990 Ruling 59283 F - Dividend Refund to Private Corporation in the Case of Non-Arm's Length Sale of Shares

By services, 18 January, 2022
Official title
Dividend Refund to Private Corporation in the Case of Non-Arm's Length Sale of Shares
Language
French
CRA tags
84.1(1)(b), 129(1)(a)(i), 129(1.2)
Document number
Citation name
59283
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632242
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-01-29 07:00:00",
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Main text
19(1) File No. 5-9283
  C. Robb
  (613) 957-2744

January 29, 1990

19(1)

Re:  Paragraph 84.1(1)(b) and subparagraph 129(1)(a)(i) of the Income Tax Act (the "Act")

We are writing in response to your letter of December 15, 1989 in which you requested our views concerning the question of whether a deemed dividend under paragraph 84.1(1)(b) is considered to be a taxable dividend for the purposes of subparagraph 129(1)(a)(i) of the Act.

In our view, a deemed dividend under paragraph 84.1(1)(b) would be considered to be a taxable dividend paid for the purposes of subparagraph 129(1)(a)(i) of the Act, provided that subsection 129(1.2) was not applicable.

In accordance with paragraph 24 of Information Circular 70-6R, the comments expressed herein do not constitute an advance income tax ruling and consequently are not binding on Revenue Canada, Taxation.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate