Respecting whether s. 39(2) applied on the payment of a previously declared dividend, CRA stated (TaxInterpretations translation):
A dividend, at the moment of declaration, becomes a debt of the corporation which declared it to the shareholder (see in particular the decision of the Supreme Court of Canada in The Custodian v. Blucher [1927] S.C.R. 420, p. 425). Therefore, we are of the view that the foreign exchange gain or loss at the time of the payment of the dividend in this situation relates to a debt and not to a transaction or event in respect of shares of the capital stock of the taxpayer. Subsection 39(2) could therefore apply.