RE:SIB - Deemed Dividendno question tendering in a non reg account is a bad idea regardless of your cost base or long term plans. in the highest tax bracket dividends are taxed about 10pts higher than cap gains at least here in bc. could also be i a situtation where u create cap losses that take years to offset depending on size wish to tender.
flip side however and surprised we havent seen them yet is that many players (banks notably for their div arb books) salivate to create dividends (tax free into ireland) and offsetting losses that they claim against ordinary income. this is a massive enterprise amongst the banks but under increasing scrutiny as evidenced by the $6bb and counting case the CRA has brought against them. the business however tends to be "riskless" whereby they want certainty of their selling price. little surprised we havent seen them yet as those in the know have pretty good idea of liklihood of a fill in the tender!