Option 2: The obligation to account for RWT on Recommended. objective. Overall efficiency: all dividends paid between companies Meets objective. Fairness/neutrality: should be optional. Meets objective. Efficiency in Option 3: The obligation to account for RWT on Not recommended. Does not meet objective. Overall efficiency: all fully-imputed dividends paid between Does not meet objective. Fairness/neutrality: companies should be maintained (status quo). Does not meet objective. Efficiency in RWT on concurrent cash and non-cash dividends Options to address concerns around the over-taxation of cash and non-cash dividends paid concurrently, as well as the unnecessary compliance costs arising from the RWT obligations which apply are: Options: Recommendations Analysis against objectives Option 1: A taxpayer should be able to opt to Recommended. Meets objective. Overall efficiency: cash and non-cash dividends paid concurrently as a Meets objective. Fairness/neutrality: single dividend, when the cash dividend is Meets objective Efficiency in costs: sufficient to cover the RWT obligations for both dividends. Option 2: A taxpayer should not be able to opt to Not recommended. Does not meet objective. Overall efficiency: treat cash and non-cash dividends paid Does not meet objective. Fairness/neutrality: concurrently as a single dividend, with the two Does not meet objective. Efficiency in costs: dividends remaining separate for the purposes of the RWT obligations (status quo). Rules which restrict commercial practice LTC restriction on share classes Options to address the concern that the restriction applying to LTC shares unduly restricts commercial practice are: Options: Recommendations Analysis against objectives Option 1: LTCs should have the option of having Not recommended. Partly objective. Overall efficiency: more than one class. Partly meets objective. Fairness/neutrality: Does not meet objective. Efficiency in costs: Option 2: A LTC should be able to have more than Recommended. Meets objective. Overall efficiency: one of shares provided all shares still have Mostly meets objective. Fairness/neutrality: uniform entitlements to distributions from the LTC Meets objective. Efficiency in costs: (i.e. differentiate on voting rights only). Option 3: LTCs should continue to be restricted to Not recommended. Does not meet objective. Overall efficiency: having just one share class (status quo). Does not meet objective. Fairness/neutrality: No impact. Efficiency in costs:
Option 2: The obligation to account for RWT on all dividends paid between companies should be optional. Recommended. Overall efficiency: objective. Fairness/neutrality: Meets objective. Efficiency in Meets objective. Option 3: The obligation to account for RWT on all fully-imputed dividends paid between companies should be maintained (status quo). Not recommended. Overall efficiency: Does not meet objective. Fairness/neutrality: Does not meet objective. Efficiency in Does not meet objective. RWT on concurrent cash and non-cash dividends Options to address concerns around the over-taxation of cash and non-cash dividends paid concurrently, as well as the unnecessary compliance costs arising from the RWT obligations which apply are: Options: Recommendations Analysis against objectives Option 1: A taxpayer should be able to opt to cash and non-cash dividends paid concurrently as a single dividend, when the cash dividend is sufficient to cover the RWT obligations for both dividends. Recommended. Overall efficiency: Meets objective. Fairness/neutrality: Meets objective. Efficiency in costs: Meets objective Option 2: A taxpayer should not be able to opt to treat cash and non-cash dividends paid concurrently as a single dividend, with the two dividends remaining separate for the purposes of the RWT obligations (status quo). Not recommended. Overall efficiency: Does not meet objective. Fairness/neutrality: Does not meet objective. Efficiency in costs: Does not meet objective. Rules which restrict commercial practice LTC restriction on share classes Options to address the concern that the restriction applying to LTC shares unduly restricts commercial practice are: Options: Recommendations Analysis against objectives Option 1: LTCs should have the option of having more than one class. Not recommended. Overall efficiency: Partly objective. Fairness/neutrality: Partly meets objective. Efficiency in costs: Does not meet objective. Option 2: A LTC should be able to have more than one of shares provided all shares still have uniform entitlements to distributions from the LTC (i.e. differentiate on voting rights only). Recommended. Overall efficiency: Meets objective. Fairness/neutrality: Mostly meets objective. Efficiency in costs: Meets objective. Option 3: LTCs should continue to be restricted to having just one share class (status quo). Not recommended. Overall efficiency: Does not meet objective. Fairness/neutrality: Does not meet objective. Efficiency in costs: No impact.
2016-ris-archcrm-bill-11.docx