The Statement looks at when the transfer of company value to a shareholder results in a dividend or employment income or a fringe benefit for tax purposes.  Its focus is very narrow and is intended to cover simple transactions that commonly occur in small and medium sized companies.  

It does not address how the dividend rules apply to transactions within a wholly-owned group, share repurchases, statutory producer boards, co-operative companies, foreign unit trusts, superannuation schemes, share-lending arrangements or emigrating companies or the rules for dealing with foreign tax credits.

We appreciate that there is a fine balance between providing enough information so that the audience sufficiently understands the subject matter and giving too much information that overwhelms the audience.  However, in our view, the Statement oversimplifies the deemed dividend rules and fails to convey how complex the rules actually are.