Ahmad v. The Queen, 2013 DTC 1112 [at at 601], 2013 TCC 127 (Informal Procedure) -- summary under Subsection 90(1)

By services, 28 November, 2015

The taxpayer held 1000 shares in a Bermudan corporation ("Tyco"). In a corporate reorganization, Tyco distributed 250 shares to the taxpayer of its two wholly owned subsidiaries, and consolidated the taxpayer's 1000 shares into 250. The taxpayer was assessed for receiving a dividend in kind.

Rip CJ upheld that the shares distributions were a dividend in kind, as Tyco had failed to file a s. 86.1 election. He stated (at para. 13):

I agree with Mr. Ahmad and his representative that Mr. Ahmad incurred no economic benefit as a result of the Tyco reorganization. However, according to the Act, he did receive dividends in kind from Tyco and the dividends had a value.

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dividend in kind on US spin-off
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