Fracto Inc. is a Canadian controlled private corporation with a December 31 year end. For the taxation year ending December 31, 2019, its Net Income For Tax Purposes was made up of the following components:

Active Business Income (Note 1)$ 514,400

Dividends From Canadian Corporations:

Wholly-Owned Subsidiary (Note 2)297,400

Portfolio Investments (All Eligible Dividends)89,600

Canadian Source Interest44,300

Taxable Capital Gains93,100

Net Income For Tax Purposes$1,038,800

Note 1As determined under ITR 5200, $326,000 of this total qualified as M&P profits. As these amounts are allocated to a province which has a special rate for M&P profits, the company calculates the federal M&P deduction.

Note 2As a result of paying these dividends, the subsidiary received a dividend refund of $52,800. None of these dividends were designated as eligible.