Income Tax Act — I-3.3 89
 a dissolution or winding-up of the subsidiary, there shall be included in computing the parent’s low rate income pool at any time in the particular taxation year that is at or after the end of the subsidiary’s taxation year (in this subsection referred to as the subsidiary’s “last taxation year”) during which its assets were distributed to the parent on the winding-up, (a) if the subsidiary was, in its last taxation year, neither a Canadian-controlled private corporation nor a deposit insurance corporation, the subsidiary’s low rate income pool immediately before the end of that taxation year; and (b) in any other case, the amount determined by the formula A + B + C - D - E - F - G - H where A is the total of all amounts each of which is the cost amount to the subsidiary of a property immediately before the end of its last taxation year, B is the amount of any money of the subsidiary on hand immediately before the end of its last taxation year, C is the amount, if any, by which (i) the total of all amounts that, if the subsidiary had had unlimited income for its last taxation year from each business carried on, and from each property held, by it in that last taxation year and had realized an unlimited amount of capital gains for that last taxation year, would have been deductible under subsection 111(1) in computing its taxable income for that last taxation year exceeds (ii) the total of all amounts deducted under subsection 111(1) in computing the subsidiary’s taxable income for its last taxation year, D is the total of all amounts each of which is the amount of any debt owing by the subsidiary, or of any other obligation of the subsidiary to pay any amount, that was outstanding immediately before the end of its last taxation year, E is the paid up capital, immediately before the end of its last taxation year, of all of the issued and outstanding shares of the capital stock of the subsidiary, F is the total of all amounts each of which is a reserve deducted in computing the subsidiary’s income for its last taxation year, G is (i) if the parent is not a private corporation in the particular taxation year, the subsidiary’s capital dividend account, if any, immediately before the end of its last taxation year, and (ii) in any other case, nil, and H is the positive or negative amount determined by the formula I - J where I is the subsidiary’s general rate income pool at the end of its last taxation year, and J is the amount, if any, by which (i) the total of all amounts each of which is an eligible dividend paid by the subsidiary in its last taxation year exceeds (ii) the total of all amounts each of which is an excessive eligible dividend designation made by the subsidiary in its last taxation year. Election: non-CCPC (11) Subject to subsection (12), a corporation that files with the Minister on or before its filing-due date for a particular taxation year an election in prescribed form to have this subsection apply is deemed for the purposes described in paragraph (d) of the definition Canadian-controlled private corporation in subsection 125(7) not to be a Canadian-controlled private corporation at any time in or after the particular taxation year. Revoking election (12) If a corporation files with the Minister on or before its filing-due date for a particular taxation year a notice in prescribed form revoking, as of the end of the particular taxation year, an election described in subsection (11), the election ceases to apply to the corporation at the end of the particular taxation year. Repeated elections — consent required (13) If a corporation has, under subsection (12), revoked an election, any subsequent election under subsection (11) or subsequent revocation under subsection (12) is invalid unless (a) the Minister consents in writing to the subsequent election or the subsequent revocation, as the case may be; and (b) the corporation complies with any conditions imposed by the Minister. Dividend designation (14) A corpor