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", Canadian GST Monitor, August 2001 Number 155, p.1-- summary under Subsection 123(3) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(3) [P]ursuant to the Customs and Excise Offshore Application Act, the bringing of goods within the limits of the continental shelf of Canada for use as "designated goods" is considered, for purposes of Canadian customs laws, to be importation into Canada. ...

McGuffin, "Canada To Enact New Tax Avoidance Reporting Rules", Tax Management International Journal, February 8, 2013,Vol. 42, No. 2, 90 at 92-- summary under Advisor Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Advisor Note that in some cases a counterparty could be considered an "advisor" or "promoter". ...

Firoz Ahmed, "Substituted Property for Purposes of the Section 88(1)(d) Bump", Canadian Current Tax, Vol. 7, No. 7, April 1997, p. 70-- summary under Subparagraph 88(1)(c.3)(ii) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.3)- Subparagraph 88(1)(c.3)(ii) Where a public corporation ("Smallco") makes a successful takeover bid for another corporation ("Bigco"), RC is prepared to rule that shares of Smallco issued to shareholders of Bigco will not be considered to be substituted property by virtue of s. 88(1)(c.3)(ii) if the fair market value of the gross assets of Smallco prior to the completion of the bid is greater than 10%, but less than 50%, of the fair market value of the gross assets of Smallco after the wind-up of Bigco. ...

.-- summary under Subparagraph 88(1)(c.3)(i) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.3)- Subparagraph 88(1)(c.3)(i) Upstream equity or debt as substituted property (p. 280) Any upstream equity interests (such as shares of the parent or other upper-tier corporate or partnership interests) or debt of any upstream entities owned after the acquisition of control will constitute substituted property since the value of such property will be considered wholly or partly attributable to distributed property. ...

For example, a senior executive providing training as a part-time employee after termination would be considered to have experienced a substantial change in services. ...

Unlike the other attribution rules, this provision has a purpose element to it, in that it can apply only if it can be considered that one of the main reasons for the loan was to reduce or avoid tax by causing income from the loaned property or substituted property to be included in the income of the debtor. ...

Any other annual fees, however, that can reasonably be considered to be annual costs should be annually deductible under this paragraph. ...

If the expected cash flow and tax profile of the investment is communicated to the investor by a promoter, and if the other requisite tests are met, the major construction project or partnership interest divested to the investor could be considered a tax shelter…. ...

.-- summary under Subsection 94(8.2) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(8.2) Effect of ss. 94(8.1) and (8.2) By deeming the relevant transfers and loans not to be arm's-length transfers (as otherwise defined in subsection 94(1)), they will be considered to be contributions made to the trust by the Canadian resident. ...

Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) Not engaged merely by support agreement or arrangement agreement The entering into of a support agreement or an arrangement agreement prior to implementing an acquisition of a Canadian target should not be considered to be the granting of s. 251(5)(b) rights until the shareholders have tendered their shares or approved the transaction (p. 36: 7). ...