16 November 1990 Ministerial Letter F3868 F - Associated Corporations - Meaning of "Accrued and Unpaid Dividends" and "Unpaid Dividends"

By services, 18 January, 2022
Official title
Associated Corporations - Meaning of "Accrued and Unpaid Dividends" and "Unpaid Dividends"
Language
French
CRA tags
191(4), 256(1.1)
Document number
Citation name
F3868
Severed letter type
Ministerial Letter
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632407
Extra import data
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Main text
  November 16, 1990
Rulings Directorate Current Amendments and
Director General Regulations Division
  W.R. McColm
Attention: M. Ton-That 957-2068
  F-3868

"Accrued and Unpaid Dividends" - 191(4) and "Unpaid Dividends" - 256(1.1)

This is in reply to your memo of November 7, 1990 concerning the above terms used in the respective subsections of the Income Tax Act and whether in policy terms they are intended to have the same meaning.

The policy intention is that both expressions are intended to have the same meaning, that is, they both mean declared and unpaid dividends and, where dividends are cumulative, not declared and in arrears, include such dividends.

R. D'AurelioDirectorCurrent Amendments and Regulations Division

c.c.     B. ErneweinDepartment of Finance