Dividend Rental Agreement

Administrative Policy

18 October 1995 External T.I. 9511155 - DIVIDEND RENTAL

Where a taxable Canadian corporation (the "Borrower") borrows shares of a non-resident public corporation from an arm's length lender and...

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23 April 1992 Memorandum 921211 (September 1992 Access Letter, p. 39)

A situation in which a securities dealer would borrow a share on which either a cash dividend, or a stock dividend valued at a 5% discount from...

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IT-67R3 "Taxable Dividends from Corporations Resident in Canada"

"A dividend rental arrangement ... may generally be described as any arrangement the main reason for which is to enable a person to receive a...

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Articles

Sugg, "Preferred Share Review: Anomalies and Traps for the Unwary", 1992 Conference Report, c.22.

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