When you write proposals on the fly, there's a risk.
I have a lot of questions.
What is “taxable dividend”? Does it include the increase of the paid-up capital or not? I don't know. What's a “holder”? Can you find it in the Income Tax Act? No. Who holds, and how do you hold? What do you mean by “holder”? Who is a holder? I don't know. You will need the definition. What is a subsidiary? Is it wholly owned or partially owned? When do you decide it's a subsidiary?
This is not serious drafting. I see five problems with this particular definition. It doesn't fit in the Income Tax Act. There's a risk. If this committee wants to do some drafting, it has to be more rigorous, because we are creating a problem for taxpayers. Despite what my colleagues want to achieve, it's not rigorous and it is not the way people do drafting in this country.