November 16, 1990
Rulings Directorate Current Amendments and
Director General Regulations Division
R.R. McColmAttention: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'Aurelio Director Current Amendments and Regulations Division
cc. B. Ernewein Department of Finance