I-3 - Taxation Act

Section 592 Disposition versions

2015-12-04

592. For the purposes of sections 591, 591.1, 591.2 and 591.3, the following rules apply:

(a)  a dividend received by a corporation resident in Canada is a tax-exempt dividend to the extent of the portion of the dividend that is deductible in computing its taxable income under any of paragraphs a to c of section 746;

(b)  a dividend received by a particular foreign affiliate of a corporation resident in Canada from another foreign affiliate of the corporation is a tax-exempt dividend to the extent of the amount by which the portion of the dividend that was not prescribed to have been paid out of the pre-acquisition surplus of the other affiliate exceeds the aggregate of such portion of the income or profits tax that can reasonably be considered to have been paid in relation to that portion of the dividend by the particular affiliate or by a partnership in which the particular affiliate had, at the time of the payment of the income or profits tax, a partnership interest, either directly or indirectly; and

(c)  a foreign affiliate of a corporation resident in Canada is deemed to have received from another foreign affiliate of the corporation an amount equal to the amount that is described in paragraph c of subsection 3 of section 93 of the Income Tax Act (R.S.C. 1985, c. 1, (5th Suppl.)), at the time referred to in that paragraph and for the same purposes.

1972, c. 23, s. 453; 1975, c. 22, s. 163; 1997, c. 3, s. 71; 2004, c. 8, s. 122; 2015, c. 21, s. 204; 2015, c. 36, s. 27.

2015-10-21

592. For the purposes of sections 591, 591.1, 591.2 and 591.3, the following rules apply:

(a)  a dividend received by a corporation resident in Canada is a tax-exempt dividend to the extent of the portion of the dividend that is deductible in computing its taxable income under any of paragraphs a to c of section 746; and

(b)  a dividend received by a particular foreign affiliate of a corporation resident in Canada from another foreign affiliate of the corporation is a tax-exempt dividend to the extent of the amount by which the portion of the dividend that was not prescribed to have been paid out of the pre-acquisition surplus of the other affiliate exceeds the aggregate of such portion of the income or profits tax that can reasonably be considered to have been paid in relation to that portion of the dividend by the particular affiliate or by a partnership in which the particular affiliate had, at the time of the payment of the income or profits tax, a partnership interest, either directly or indirectly.

1972, c. 23, s. 453; 1975, c. 22, s. 163; 1997, c. 3, s. 71; 2004, c. 8, s. 122; 2015, c. 21, s. 204.

2006-03-01

592. For the purposes of sections 591 to 591.3, the following rules apply:

(a)  a dividend received by a corporation resident in Canada is a tax-exempt dividend to the extent of the portion of the dividend that is deductible in computing its taxable income under any of paragraphs a, b and c of section 746; and

(b)  a dividend received by a particular foreign affiliate of a corporation resident in Canada from another foreign affiliate of the corporation is a tax-exempt dividend to the extent of the amount by which the portion of the dividend that was not prescribed to have been paid out of the pre-acquisition surplus of the other affiliate exceeds the aggregate of such portion of the income or profits tax that can reasonably be considered to have been paid in relation to that portion of the dividend by the particular affiliate or by a partnership in which the particular affiliate had, at the time of the payment of the income or profits tax, a partnership interest, either directly or indirectly.

1972, c. 23, s. 453; 1975, c. 22, s. 163; 1997, c. 3, s. 71; 2004, c. 8, s. 122.