There are significant attributes in the tax treatment of shareholder debt and shareholder equity from the perspective of both a CCPC and its shareholders. Which of the following is an example of a tax consequence on return of investment of shareholder equity?

a) Dividends received by a CCPC from taxable Canadian corporations are deducted from net income for tax purposes to reduce the corporation's taxable income.

b) A loss on the investment is typically a capital loss which may potentially qualify as an ABIL.

c) Interest is taxed in the hands of the shareholder at a marginal tax rate for regular income.

d) Sale of shares back to the corporation may result in a S.84(3) deemed dividend and capital gain or loss.