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Technical Interpretation - External
23 September 1993 External T.I. 9325845 F - HAA7255-3 RRSP Benefits and Contests
The Department's position concerning lotteries and contests is that if the prizes being offered are deposited directly into the RRSPs of the contest winners and no receipts for the contributions are offered to the annuitants the promotion will not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act (the "Act"). ... The Department's position with respect to the offering of a publication such as a book or booklet to the annuitant of an RRSP is that the offer will contravene the provisions of paragraph 146(2)(c.4) of the Act and the provisions of subsection 146(13.1) of the Act can be applied if the offer is linked in any manner to the issue or existence of an RRSP. A publication that is offered free to anyone making an RRSP contribution will contravene this rule even if it is available to other customers. ...
Technical Interpretation - External
20 November 1990 External T.I. 9029585 F - Bonus Interest Paid into RRSP as Advantage Extended to Annuitant
This "bonus" interest would be paid into an RRSP rather than to the annuitant and you ask if this would contravene paragraph 146(2)(c.4) of the Act. It is our view that payment of bonus interest into an RRSP does not contravene paragraph 146(2)(c.4) of the Act. ...
Miscellaneous severed letter
7 November 1990 Income Tax Severed Letter 158
This "bonus" interest would be paid into an RRSP rather than to the annuitant and you ask if this would contravene paragraph 146(2)(c.4) of the Act. It is our view that payment of bonus interest into an RRSP does not contravene paragraph 146(2)(c.4) of the Act. ...
Miscellaneous severed letter
20 November 1990 Income Tax Severed Letter
This "bonus" interest would be paid into an RRSP rather than to the annuitant and you ask if this would contravene paragraph 146(2)(c.4) of the Act. It is our view that payment of bonus interest into an RRSP does not contravene paragraph 146(2)(c.4) of the Act. ...
Technical Interpretation - External
15 June 2020 External T.I. 2020-0850981E5 - CECRA – Pension plan eligibility
Although the forgivable loan would contravene the narrower borrowing restriction in paragraph 8502(i), the CRA will exercise its discretion to not revoke the registration of an RPP for failure to comply with this condition. ... Based on our review of the Act, the ITR and the program documentation, our views are as follows: Participating in the CECRA with respect to commercial property held by a pension real estate corporation will not contravene the borrowing restriction in clause 149(1)(o.2)(ii)(C). Although participating in the CECRA by an RPP will contravene the narrower borrowing restriction in paragraph 8502(i), the CRA will exercise its discretion to not revoke the registration of an RPP for failure to comply with this condition. ...
Technical Interpretation - External
9 January 1997 External T.I. 9640105 - REIMBURSEMENT OF RRSP ADMIN FEES
XXXXXXXXXX 964010 Attention: XXXXXXXXXX January 9, 1997 Re: Registered Retirement Savings Plan ("RRSP") Trustee or Administration Fees This is in reply to your facsimile transmission of December 3, 1996, in which you ask whether the payment of the above-noted fee by the agent of the RRSP trustee would contravene paragraph 146(2)(c.4) of the Income Tax Act (the "Act"). ... Thus it is our view that where the terms of the RRSP plan document provide that the trustee or administration fee may be recovered from the plan funds, the payment of such a fee either with plan funds or by the agent of the RRSP trust does not contravene the condition in paragraph 146(2)(c.4) of the Act. ...
Technical Interpretation - External
2 May 1996 External T.I. 9611675 - RRSP INVESTMENT IN NON-ARM'S LENGTH MORTGAGE
Reasons: Contravenes 146(2)(c.4) inasmuch as it is an advantage to the non-arm's length mortgagor; may contravene 4900(1)(j) if collection by annuitant results in mortgage not being "administered" by an approved lender. 961167 XXXXXXXXXX P. ...
Miscellaneous severed letter
28 June 1988 Income Tax Severed Letter 7-2949 - [Proposed amendment to a RRIF]
Noack 957-8963 Attention: Cecilia Lam---------------------- SUBJECT:XXXX We reply to your memorandum of June 6 concerning a proposed amendment to a RRIF issued by XXXX You ask whether subsection 4(1) of the amended plan would contravene the requirement in paragraph 146.3(2)(g) that no benefit that is conditional on the existence of the plan may be extended to the annuitant. ... Therefore, the provision for payment of a guaranteed amount as intended by subsection 4(1) of the amended plan does not contravene the condition for acceptance for registration in paragraph 146.3(2)(g). for Director Financial Industries Division Rulings Directorate ...
Miscellaneous severed letter
7 October 1987 Income Tax Severed Letter 5-3801 - [Deferred Compensation/Leave of Absence Plan]
Paragraph 3(a) on page 1 of the document titled "Facts and Proposed Transactions" when read in conjunction with paragraph two of the Memorandum of Agreement (the "Agreement") may contravene clause 6801(a)(i) of the Regulations as the total deferral period may exceed six years which is the maximum allowed under the Regulations. 2. Clause 3(f)(ii) of the Agreement contravenes clause 6801(a)(i) of the Regulations as the leave period must not be of less than six months and the deferral period, as mentioned before, must not exceed six years. 3. ...
Technical Interpretation - External
20 August 2018 External T.I. 2018-0739761E5 - TFSA contributions
20 August 2018 External T.I. 2018-0739761E5- TFSA contributions Unedited CRA Tags 146.2(2)(c), 207.01(1) "advantage", 74.1(2) Principal Issues: Whether payments made by a third party on behalf of an individual directly to their TFSA in several scenarios contravene the condition in paragraph 146.2(2)(c) that prohibits anyone other than the holder from making contributions to the TFSA. ... Doiron August 20, 2018 Dear XXXXXXXXXX: Re: Contributions to a tax-free savings account This is in reply to your email of January 15, 2018 in which you ask for confirmation that payments made to a tax-free savings account (“TFSA”) in each of the following three scenarios do not contravene the condition in paragraph 146.2(2)(c) (footnote 1) that prohibits anyone other than the holder from making contributions to the TFSA. ...