CRA , respecting the winding-up of a non-profit organization described in s. 149(1)(l):
If the association is a corporation with capital stock, subsection 84(2) could apply to the transfer of property to the shareholders so that the corporation is deemed to have paid a dividend to them. Under subsection 84(2), the shareholder will be deemed to have received that dividend. However, if the association does not have capital stock, such a transfer to a member could be a payment on account of capital and represent the proceeds of disposition of a member's interest. In the latter situation, subsection 84(2) would not apply.