Deemed dividend: company loans or payments for shareholder benefit treated as taxable income when from accumulated profits. A payment by a closely held company in the form of an advance, loan, or payment for the individual benefit of a qualifying shareholder or a concern in which the shareholder has substantial interest is recharacterised as deemed dividend to the extent the company possesses accumulated profits; this targets beneficial owners holding at least ten percent of voting power in companies not substantially owned by the public.