After noting the Court’s comments Gladwin Realty Corporation v Canada, 2020 FCA 142, aff’g 2019 TCC 62, at ΒΆ76, the authors conclude “that CDA timing strategies are not offensive in general”. Capital dividends can be paid immediately after the realization of gains; a taxpayer need not wait for losses to be realized.
Matthew Rahman and Chelsey Sherloski, “FCA: CDA Duplication Is Abusive” Canadian Tax Focus 10:4 (November 2020)
