29 November 2011 Roundtable, 2011-0426361C6 F - Price adjustment clause and redemption of shares -- summary under Effective Date

CRA indicated that where there is subsequent payment to the redeemed shareholder as the result of the operation of a price adjustment clause to increase the redemption amount of preferred shares, the s. 84(3) dividend (and any resulting s. 129(1) dividend refund) is considered to have occurred in the year the additional payment was made rather than in the earlier year of redemption.