Chapter 6 - Page 6 of the T2 return

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• Refundable portion of Part I tax
  • Lines 440, 445, and 450
• Refundable dividend tax on hand
  • Lines 460, 465, 480, and 485
• Dividend refund
  • Parts 3 and 4 of Schedule 3

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Refundable portion of Part I tax

Lines 440, 445, and 450

The refundable portion of Part I tax is part of the refundable dividend tax on hand (RDTOH). More information about RDTOH is in the section that follows.

The refundable portion of Part I tax allows a CCPC that has paid Part I tax on investment income to recover part of that tax when the corporation pays taxable dividends to its shareholders. The refundable portion of Part I tax only applies to corporations that are CCPCs throughout the tax year.

The refundable portion of Part I tax is based on the aggregate investment income and foreign investment income. You have to determine these amounts by completing Parts 1 and 2 of Schedule 7, Calculation of Aggregate Investment Income and Active Business Income.

Part 1 - Aggregate investment income calculation

The aggregate investment income is the aggregate world source income calculated as follows:

add

• the eligible portion of the taxable capital gains for the year that is more than the total of:
  • the eligible portion of allowable capital losses for the year; and
  • the net capital losses from previous years which are applied in the year;
• total income from property (including income from a specified investment business carried on in Canada other than income from a source outside Canada) from which the following amounts have been deducted:
  • exempt income;
  • Net Income Stabilization Account (NISA) receipts;
  • taxable dividends deductible after deducting related expenses; and
  • business income from an interest in a trust that is considered property income under paragraph 108(5)(a);

deduct

• total losses for the year from property (including losses from a specified investment business carried on in Canada other than losses from a source outside Canada).

On line 440 enter the amount of aggregate investment income that you determined on line O of Schedule 7.

You can include taxable capital gains and allowable capital losses in a CCPC's net investment income only if you can attribute the gain or loss to a period of time when a CCPC, an investment corporation, a mortgage investment corporation, or a mutual fund corporation held the disposed property.

Part 2 - Foreign investment income calculation

The foreign investment income is all income from only sources outside of Canada calculated as follows:

add

• the eligible portion of the taxable capital gains for the year that is more than:
  • the eligible portion of allowable capital losses for the year;
• the total income from property from a source outside Canada from which the following amounts have been deducted:
  • exempt income;
  • taxable dividends deductible after deducting related expenses; and
  • business income from an interest in a trust that is considered property income under paragraph 108(5)(a);

deduct

• the total losses for the year from property from a source outside Canada.

On line 445 enter the amount of foreign investment income that you determined on line AA of Schedule 7.

Calculate the amount of the refundable portion of Part I tax. Enter the amount from line 450 in the space provided in the "Refundable dividend tax on hand" area of your return.

References
Subsections 129(3) and 129(4)
IT-73, The Small Business Deduction
IT-269, Part IV Tax on Taxable Dividends Received by a Private Corporation or a Subject Corporation

Refundable dividend tax on hand

Lines 460, 465, 480, and 485

The RDTOH account only applies to corporations that were private or subject corporations.

A CCPC generates RDTOH on both the Part I tax it pays on investment income, and on the Part IV tax it pays on dividends it receives. For any other type of private corporation, only the Part IV tax it pays generates RDTOH.

For more information on taxable dividends deductible under section 112 or 113, or subsection 138(6), see line 320.

For information on Part IV tax and instructions to complete Schedule 3, see line 712 - Part IV tax payable.

All or part of the RDTOH at the end of the tax year is available as a refund if the corporation pays taxable dividends to the shareholders during the tax year.

To calculate the RDTOH at the end of the tax year, add the following amounts:

• the RDTOH balance at the end of the previous tax year (minus any dividend refund issued to the corporation in the previous year);
• the refundable portion of Part I tax from line 450;
• Part IV tax calculated on line 360 of Schedule 3; and
• any balance of RDTOH transferred from a predecessor corporation on amalgamation, or from a wound-up subsidiary corporation.

For the first tax year of a successor corporation formed as a result of an amalgamation, enter on line 480 all RDTOH balances being transferred from predecessor corporations. Do not include this amount on line 460.

For a parent corporation that wound up a wholly owned subsidiary, enter on line 480 any RDTOH transferred from the subsidiary corporation. On line 460, enter the RDTOH the parent corporation is carrying forward from its previous tax year.

Note
You cannot transfer any RDTOH to a successor or parent corporation if, had the predecessor or subsidiary corporation paid a dividend immediately before the amalgamation or wind-up, subsection 129(1.2) would have applied to that dividend.

On line 485, enter the RDTOH at the end of the tax year. Also, enter the same amount on line J in the "Dividend refund" area of your return.

References
Subsections 129(3) and 186(5)

Dividend refund

A private or subject corporation may be entitled to a dividend refund for dividends it paid while it was a private or subject corporation, regardless of whether it was a private or subject corporation at the end of the tax year.

Note
To claim a dividend refund or to apply the amount to another debit for any tax year, including the same tax year, you have to file your income tax return within three years of the end of the tax year.

A dividend refund arises if you pay taxable dividends to shareholders, and if there is an amount of RDTOH at the end of the tax year.

To claim a dividend refund, you have to have made an actual payment to the shareholders, unless the dividend is considered paid (a deemed dividend).

You can make this payment either in cash, or with some other tangible assets at fair market value, including the following:

• stock dividends;
• section 84 deemed dividends; and
• amounts paid as interest or dividends on income bonds or debentures that are not deductible when calculating income.

If you lose your private status following a change in control, a deemed year-end occurs. This allows you to claim a dividend refund for any dividends paid during the deemed short year.

You have to complete Parts 3 and 4 (if they apply) of Schedule 3 to claim a dividend refund. The dividend refund is equal to whichever of the following amounts is less:

• 1/3 of taxable dividends that you paid in the year while a private or subject corporation; or
• the RDTOH at the end of the tax year.

The total of taxable dividends paid for the purpose of the dividend refund is equal to the amount on line 460 of Schedule 3. Refundable dividend tax on hand refers to the amount on line 485 in the "Refundable dividend tax on hand" area of your return.

Parts 3 and 4 of Schedule 3

The following explains how to complete Parts 3 and 4 of Schedule 3. Parts 1 and 2 are explained at How to complete Parts 1 and 2 of Schedule 3.

If you paid taxable dividends during the year, complete Part 3 to identify taxable dividends that qualify for the dividend refund.

If the amount of dividends paid includes dividends that do not qualify for the dividend refund, you have to deduct these dividends before completing the calculation in Part 3. In this case, complete Part 4 of Schedule 3 to identify dividends that do not qualify.

Dividends that do not qualify are:

• dividends paid out of the capital dividend account;
• capital gains dividends;
• dividends paid for shares that do not qualify as taxable dividends, because the main purpose of acquiring the shares was to receive a dividend refund [subsection 129(1.2)];
• taxable dividends paid to a controlling corporation that was bankrupt at any time in the year; and
• deemed dividends paid on a small business development bond.

Complete Part 3 of Schedule 3 to identify a connected corporation that received taxable dividends that qualify for the dividend refund.

If the dividend refund is more than the amount of Part I tax payable for the year, we deduct the excess from any other taxes owed under the Income Tax Act. Any balance left over is available for a refund.

If the total dividends paid during the year is different from the total of taxable dividends paid for the purpose of the dividend refund, complete Part 4 of Schedule 3.

References
Section 129
Subsection 186(5)

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