significant

17 November 2015 Roundtable, 2015-0613821C6 - TEI question on section 55 -- summary under Paragraph 55(2.1)(b)

TEI members remain concerned that, because all dividends result in a reduction of the fair-market value of shares held by the dividend payor and increase the cost of properties held by the dividend recipient, the CRA may try to reassess ordinary course dividends on the basis that a purpose of every dividend is a tainted purpose. Comments? CRA responded:

The "significant" aspect could be measured in terms of an absolute dollar amount or on a percentage basis.

3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand -- summary under Paragraph 55(2.1)(b)

CRA declined to express a view as to whether an $8,000 reduction in an accrued capital gain of $120,000 was significant. A $50,000 dividend received by two Holdcos from Opco (with no indication of the total FMV of all the shares) would be considered to be significant.

3 November 1997 External T.I. 9725615 - INCREASE IN INTEREST -- summary under Paragraph 55(3)(a)

"In circumstances where no person has acquired any shares of the corporation in question, it is our view that for the purposes of determining whether there has been 'a significant increase ... in the total direct interest' of an unrelated person in the corporation for purposes of ...

By services, 28 November, 2015

Canada v. VIH Logging Ltd., 2005 DTC 5095, 2005 FCA 36 -- summary under Subsection 55(2)

Cash dividends paid by a corporation ("Old VIH") to its parent (the taxpayer) in February 1993 came out of safe income of Old VIH given that the computation of Old VIH's safe income included significant income that it had earned after its last fiscal year end (March 31, 1992) and before the date of payment of the dividends. Sharlow J.A. stated (at p. 5101) that

significant

significant

Term Tree