Characterisation for treaty purposes of manufactured dividends received in terms of securities lending arrangements

Equity securities lending arrangements are contracts whereby a shareholder lends his shares to a borrower for a period of time. If dividends are declared during that period, these accrue to the borrower, and the borrower pays a manufactured dividend to the lender as compensation. The applicable inco...

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Bibliographic Details
Main Author: Vanlierde, Angela
Other Authors: West, Craig
Format: Dissertation
Language:English
Published: Faculty of Commerce 2021
Subjects:
Online Access:http://hdl.handle.net/11427/32781