The economic impacts of COVID-19 relief programs directly intersect with tax law. As the system becomes more stressed for tax revenue, discussions about seemingly immutable topics are bound to return. What was once forsaken is up for discussion. The passive investment income of private corporations is one such topic. I discuss this below. […]
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Two Mischiefs and Internal Consistency: Excessive Eligible Dividends
How does the Income Tax Act know if a corporation has the capacity to pay an eligible dividend? If an eligible dividend is good for the taxpayer because it means less personal tax payable, surely the Act must police this area of the law. Below, I detail the policing regime and the purposes motivating […]
Deriving and Understanding Dividend Gross-Up Rates
Have you ever wondered why the dividend gross-up rates are what they are? Allow me to do some basic high school math to show you. Integration and its Purpose Understanding the math requires an appreciation of the purpose of dividend income “integration.” The purpose of integrating dividend income (disregarding capital dividends) is to […]