A capital distribution by Intrepid Mines will be treated similarly for Canadian and Australian purposes

Intrepid Mines, an Australian company listed on the ASX and TSX, is proposing to distribute approximately 87% of its assets in cash as a capital distribution.  It is anticipated that the Australian Taxation Office will publish a "class" ruling on its website indicating that the distribution will be treated as a basis reduction rather than a dividend for Australian purposes for those shareholders who do not hold their shares as revenue assets.  Essentially the same treatment is anticipated for Canadian income tax purposes for most Canadian shareholders based on the distribution’s treatment as a return of capital for Australian corporate purposes.

Neal Armstrong.  Summary of Intrepid Mines Explanatory Memorandum under Spin-Offs & Distributions – Foreign capital distributions.