Traduction de «dividende réputé » (Français → Anglais) :

deemed dividend

deemed dividend

distribution of a dividend | dividend disbursement | dividend distribution | dividend payment | dividend payout | dividends paid | payment of a dividend

digital reputation | online reputation | electronic reputation | e-reputation

dividend policy

corporate image | corporative image

online reputation [ cyber reputation ]

Down the chain, payment is either a deemed dividend from CanCo to Parent today, or, under the rules that allow for this in certain circumstances, the deemed dividend is replaced with a reduction of the paid up capital of CanCo shares that will produce a deemed dividend later, when CanCo goes to make a distribution and finds its paid up capital gone.

(f) all amounts included in the individual’s income for the taxation year pursuant to subsection 82(1) or 90(1) in respect of taxable dividends received (other than dividends deemed by section 84 to have been received) by the individual in the year on shares that were received from the corporation as consideration for the transfer or as repayment for the loan that were excluded consideration at the time the dividends were received or on shares substituted therefor that were excluded consideration at that time, and

and the terms or conditions of the share or the agreement in respect of the share specify an amount in respect of the share, including an amount for which the share is to be redeemed, acquired or cancelled (together with, where so provided, any accrued and unpaid dividends thereon) and where paragraph 191(4)(a) applies, the specified amount does not exceed the fair market value of the consideration for which the share was issued, and where paragraph 191(4)(b) or 191(4)(c) applies, the specified amount does not exceed the fair market value of the share immediately before the particular time, the amount of any dividend deemed to have been ...[+++]paid on a redemption, acquisition or cancellation of the share to which subsection 84(2) or 84(3) applies shall

Treating a payment down the chain as if it were a payment up in Canada is a real change in tax policy and could potentially trigger double taxation because, when CanCo makes the payment to ForeignCo — a deemed dividend for Canadian purposes — dividend-withholding tax applies.