6 February 1990 Administrative Letter 59346 F - Declaration of Dividends and their Effect on Value of Preference Shares

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

February 6, 1990

Dear Sirs:

Re:  Declaration of Dividends and their effect on the value of Preference Shares

We refer to your letter of December 28, 1989, in which you asked us to comment on the following situation.

24(1)

You have asked us to advise you whether the Department would have difficulty with this situation in either of the following two respects:

24(1)

Comments

It appears that your request relates to a specific situation in respect of which no proposed transactions are contemplated.  We are unable to comment on the situation, since this would only be possible following a review of all the relevant facts pertaining to the situation.  Also, as the responsibility for determining the tax consequences arising from actual completed transactions rests with the district taxation offices, the appropriate district taxation office may, upon disclosure of all relevant facts, be able to assist you in clarifying the tax consequences pertaining thereto.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch