After noting that payment of two back-to-back capital dividends (from “Subco” to “Parentco,” and form it to its individual shareholder) had been accomplished only by accounting entries, the Directorate found that this was insufficient to give rise to a capital dividend “received” by Parentco, so that there had been no addition to its capital dividend account. In this regard, it stated:
[T]he mere making of the accounting entries … does not in itself constitute the payment of a dividend … by either Subco or Parentco. …
[H]owever … a dividend can be paid by a corporation and received by its recipient without any monetary movement, for example, by the issuance of a demand note that is accepted as an absolute payment by the recipient.