Opco incurred a non-capital loss (an "NCL") in each of its 2019 and 2020 taxation years (the 2019 and 2020 Loss Years), and carried back the 2019 NCL to its 2016 and 2017 taxation years, and its 2020 NCL incurred in 2020 to the 2017 and 2018 taxation years (the 2016, 2017 and 2018 Application Years) so as to reduce its taxable income to nil for the Application Years. In the 2020 Loss Year, Opco paid two taxable dividends of $200 each to its corporate shareholder, which it designated as eligible dividends.
CRA indicated that a corporation's GRIP at the end of a taxation year in which it has a loss which is carried back will thereby be reduced at the end of that year by virtue of B of the GRIP formula. Consequently, Opco's 2019 Loss Year NCL (that was carried back to 2016 and 2017) reduce its GRIP at the end of its 2019 Loss Year; and similarly, Opco's 2020 Loss Year NCL (that was carried back to 2017 and 2018) reduces its GRIP at the end of its 2020 Loss Year.