CRA confirms that recurring shareholder advances and dividend set-offs are not a series of transactions

In IT-119R4, CRA stated that "bona fide repayments of shareholder loans that result from…the payment of dividends…are not part of a series of loans or other transactions and repayments."  CRA has confirmed that the exemption in s. 15(2.6) from the shareholder loan rule in s. 15(2.6), for timely loan repayments that do not occur as part of a series, would be available where monthly shareholder advances are partially paid off with an annual dividend (with the balance paid off with the next year’s annual dividend on a FIFO assumption).

Neal Armstrong.  Summary of 10 January 2014 T.I. 2013-0506571E5 F under s. 15(2.6).