CRA permits a Canadian public company to effect a separate s. 84(2) distribution of non-sale cash

Most or all s. 84(2) rulings for paid-up capital distributions by a public company have described a distribution of the shares of one or more subsidiaries of the public company, or the distribution of proceeds of the sale of such shares or of the assets of a business carried on directly.

CRA has issued a ruling letter that permits a public corporation, engaged in a refocusing of its business, to make two separate PUC distributions of both the proceeds of sale of a business and of surplus cash on hand.

Neal Armstrong.  Summary of 2013 Ruling 2012-0470281R3 ("Reduction of paid-up capital") under s. 84(2).