PGNX will use its PUC in advance of its final liquidation distribution

PGNX Capital Corp. has sold all its assets and has or will distribute the net proceeds in three tranches: a stated capital distribution on November 15, 2013; a distribution that will only partly be a stated capital distribution (as there is estimated to be insufficient remaining stated capital of all of it to be a capital distribution) on December 19, 2013; and a distribution pursuant to liquidation proceedings.

The tax disclosure indicates that even if a shareholder resolution is not passed to authorize the applicable portion of the second distribution to occur as a stated capital distribution, there may still only be a deemed dividend arising under s. 84(2) on the second distribution to the extent of the Corporation’s remaining paid-up capital.

Due bills attached to the PGNX shares would effectively mean that trades in the shares after the record date and before the payment time would entitle the purchaser to receive the second cash distribution.

Neal Armstrong.  Summary of Circular of PGNX Capital Corp. under Spin-Offs and Distributions - Liquidations.