Respecting the treatment of the winding up of an agricultural cooperative within the meaning of s. 135.1(1) pursuant to which the cooperative distributes the balance of its assets to its members (with such distribution not satisfying the definition of "allocation in proportion to patronage” in s. 135(4).
Provided that the distribution of property to members is not connected to tax deferred cooperative shares within the meaning of subsection 135.1(1) (footnote 1), we are of the view that the general rules relating to winding ups apply to determine the tax consequences of such distribution to members. Thus, it is possible that subsection 84(2) applies in order to deem the corporation to have paid a dividend ... .