25 July 2022 External T.I. 2021-0922321E5 - Wage Subsidy-Application of 125.7(2.01) and (14.1) -- summary under Subsection 125.7(2.01)

Q.10 Does the wage subsidy denial under s. 125.7(2.01) equal 100% of its amount for a qualifying period even if the dividend amount is less? CRA responded:

Subsection 125.7(2.01) of the Act contains no requirement for the payment of a certain amount of taxable dividends in order for it to apply. Accordingly, for the twenty-third qualifying period and subsequent qualifying periods, a publicly traded company or a subsidiary of such a company will not be entitled to the Wage Subsidy in respect of a qualifying period if any taxable dividend is paid in that qualifying period to an individual who is a holder of common shares of the company.

Q.11 Do public companies have to determine what proportion of dividends are paid to an individual? CRA indicated that para. (b) of A in the s. 125.7(14.1) formula represents the amount of those common share dividends paid by the eligible entity to “holders” who are individuals, so that the eligible entity must determine the amount of dividends paid (in the 24th and subsequent qualifying periods) on its common shares to holders who are individuals.

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