16 November 1990 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657730
Extra import data
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Main text

November 16, 1990

Rulings Directorate                Current Amendments and
Director General                    Regulations Division
                                   R.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'Aurelio Director Current Amendments and Regulations Division

cc. B. Ernewein Department of Finance