10 June 2013 STEP CRA Roundtable, 2013-0480361C6 - 2013 STEP, QUESTION 12. RDTOH and Dividend Refunds -- summary under Subsection 129(1.2)

" In response to a request for an update on its position on s. 129(1.2), CRA noted that it had issued favourable s. 129(1.2) rulings on post-mortem estate planning transactions (2004-008855, 2010-0377601R3 and 2012-0456221R3) and further stated that where the purpose test in s. 129(1.2) was met, s. 129(1.2) could technically apply to deny a dividend refund to a payer corporation even if tax was paid by the shareholder on the dividend received from the payer corporation.