A corporate payor doesn’t get a refund if it pays a dividend but fails to file its tax return for the year within three years. But at least RDTOH isn’t reduced either. See Dino Infanti, “FCA Agrees: Dividend Refund Timed Out and RDTOH Remains Intact” Tax for the Owner-Manager 16:1 (January 2016), commenting on 1057513 Ontario Inc. v R, 2015 FCA 207.
