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IT-243R4, para 5-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt mere crediting of account "A corporation is not considered to have paid a dividend when it merely credits a shareholder's account, unless the shareholder is able to withdraw the money credited at any time. ...

However, a repackaged tax shelter could be considered to be a new tax shelter. ...

.- Q.62-- summary under Subsection 112(2.1) Summary Under Tax Topics- Income Tax Act- Section 112- Subsection 112(2.1) Factors considered in determining whether shares were acquired in the ordinary course, including whether the funds raised on issuance provided need capital for the subsidiary, and whether the shares were acquired as consideration on the sale of a business or part of a business where the holder's business had not previously included such transactions. ...

.- Q10-- summary under Subsection 231.1(1) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1) Where the auditors' working papers contain closing or balancing adjustments that are relevant to the tax returns, these working papers are considered an extension of the clients records for purposes of the tax audit. ...

31 May 1993 Memorandum (Tax Window, No. 32, p. 15, ¶2613)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) A list of the factors considered in determining whether a taxpayer is carrying on business in Canada. ...

.- Q. 1-- summary under Subparagraph 212(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Subparagraph 212(1)(b)(vii) In a situation wherein a loan agreement states that there is an event of default if there is a change in control of the borrower, such event is generally considered an 'event of default'. ...

IT-81R "Partnerships- Income of Non-Resident Partners"-- summary under Subsection 120(1) Summary Under Tax Topics- Income Tax Act- Section 120- Subsection 120(1) Income that becomes subject to Part I as a result of an s. 216 election is not considered to be earned in any particular province. ...

No. 1, p. 9, ¶1000)-- summary under Section 206.1 Summary Under Tax Topics- Income Tax Act- Section 206.1 The holder of an exchangeable debenture who exercise the right of exchange will be considered to have acquired the underlying shares for consideration equal to their fair market value. ...

9 February 1990 Memorandum (July 1990 Access Letter, ¶1313)-- summary under Paragraph 8(1)(h) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h) Tree planters who report to several job sites in the course of the year and who cannot be considered to regularly or ordinarily report to any one place of business of the employer, can clearly meet the "in different places" requirement. ...

.- Q.8-- summary under Subsection 75(2) Summary Under Tax Topics- Income Tax Act- Section 75- Subsection 75(2) A genuine loan to a trust, or the unpaid purchase price for a property on an unconditional bona fide sale, will not by itself be considered to result in property being held by the trust on the conditions set out in s. 75(2)(a) and (b). ...