26 April 1990 Income Tax Severed Letter ACC9149 - Proper Reporting of Interest and Dividends Due at Year-end

19(1)                    5-900300
                                              R.B. Day
                                              613-957-2136

April 26, 1990                                EACC 9149

                 19(1)

Further to your telephone conversation of April 5, 1990 with Mr. E. Wheeler of this Division, we are writing with respect to your article of March 29, 1990, concerning the proper reporting of interest and dividends due at year-end, where one brokerage firm credited similar amounts on January 2, 1990.

In view of the confusion that may have been created by the differing views expressed by various persons quoted in the article, we would like to make the following comments.

It is the Department's view that dividend are included in a taxpayer's income when received (see subsections 82(1) and 90(1) of the Income Tax Act). An amount is considered to have been received by a taxpayer when it is received by the taxpayer or by a person authorized to receive payment on his or her behalf, in this case the broker. The taxation year of receipt is a matter of fact and not one of choice by the taxpayer.

I trust that this will be of assistance to you and regret any inconvenience that we may have caused you Yours truly,

Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch