On December 1, 2004, the appellant (AAM), which held all the (Class A and B) shares of a private corporation (Bakorp) (i) resolved to increase the stated capital of the Class A Bakorp shares by $35 million (resulting in a deemed dividend in that amount) and (ii) received two promissory notes aggregating $77.6 million in satisfaction of dividends declared on that date on the Class A and B shares.