Superior has 90 days from the initial Notice of Reassessment to prepare and file a Notice of Objection which would be reviewed by the CRA's appeals division. Superior anticipates filing a Notice of Objection in the next 30 days. After 90 days if the CRA has not responded or settled the Notice of Objection with Superior, then an application can be made to the Tax Court of Canada. Superior anticipates that if the application proceeds in the Tax Court of Canada a decision could be rendered by the end of fiscal 2014. If a decision of the Tax Court of Canada were to be appealed, the appeal process could reasonably be expected to take an additional 2 years. If Superior receives a positive decision then any taxes, interest and penalties paid to the CRA will be refunded plus interest and if Superior is unsuccessful then the remaining 50% of the taxes payable noted above will have to be remitted.
The impact of the Notice of Reassessment on Superior's tax position has been considered by management however its best estimate of the most likely outcome has not changed. In the event that the CRA is successful in this case, Superior's pools at risk is the $1,013.0 million recognized as part of the Conversion.
14. Total Equity
Superior is authorized to issue an unlimited number of common shares and an unlimited number of preferred shares. The holders of common shares are entitled to dividends if, as and when, declared by the Board of Directors: to one vote per share at meetings of the holders of common shares; and upon liquidation, dissolution or winding up of Superior to receive pro rata the remaining property and assets of Superior, subject to the rights of any shares having priority over the common shares, of which none are outstanding.
Preferred shares are issuable in series with each class of preferred share having such rights as the Board of Directors may determine. Holders of preferred shares are entitled, in priority to holders of common shares, to be paid ratably with holders of each other series of preferred shares the amount of accumulated dividends, if any, specified to be payable preferentially to the holders of such series upon liquidation, dissolution or winding up of Superior. Superior does not have any preferred shares outstanding.
Issued Number of Common Shares Total (Millions) Equity----------------------------------------------------------------------------Total equity, December 31, 2012 112.8 383.0 Net earnings - 31.4 Other comprehensive income - 12.5 Option value associated with the redemption of convertible debentures - (0.4) Shares issued under Dividend Reinvestment Plan 0.3 3.6 Issuance of common shares 13.0 137.8 Dividends declared to shareholders (1) - (17.6)----------------------------------------------------------------------------Total equity, March 31, 2013 126.1 550.3----------------------------------------------------------------------------(1Dividends to shareholders are declared at the discretion of Superior.) During the three months ended March 31, 2013, Superior paid dividends of $16.9 million or $0.13 per share (March 31, 2012 - $16.7 million or $0.15 per share). March 31, December 31, 2013 2012----------------------------------------------------------------------------Accumulated other comprehensive loss before reclassification Currency translation adjustment Balance at the beginning of the period (22.8) (13.8) Unrealized foreign currency gains (losses) on translation of foreign operations 7.8 (9.0)---------------------------------------------------------------------------- Balance at the end of the period (15.0) (22.8)---------------------------------------------------------------------------- Actuarial defined benefits Balance at the beginning of the period (25.3) (31.4) Actuarial defined benefit gains 6.1 7.2 Income tax expense (1.4) (1.1)---------------------------------------------------------------------------- Balance at the end of the period (20.6) (25.3)---------------------------------------------------------------------------- Total accumulated other comprehensive loss before reclassification (35.6) (48.1)----------------------------------------------------------------------------Amounts reclassified from accumulated other comprehensive loss Accumulated derivative gains (losses) Balance at the beginning of the period (6.0) (6.0) Reclassification of derivative gains previously deferred(1) - ----------------------------------------------------------------------------- Balance at the end of the period (6.0) (6.0)---------------------------------------------------------------------------- Total amounts reclassified from accumulated other comprehensive loss (6.0) (6.0)--------------------------------------------------------------------------------------------------------------------------------------------------------Accumulated other comprehensive loss at the end of the period (41.6) (54.1)--------------------------------------------------------------------------------------------------------------------------------------------------------(1) The reclassification of derivative gains previously deferred are included in unrealized losses on derivative financial instruments on the statement of net earnings.
