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Principal Issues: 1) Amendment to proposed transactions describing residence of general partner, types of limited partners, fuller description of management fees, and to amend rulings to confirm description in partnership agreement of limited partners' interests comply with Regulations and agreement as a whole does not contravene specific provisions in Regulation. 2) Can we rule that the terms of a partnership, as set out in a draft agreement, comply with the definition of "qualified limited partnership" in subsection 5000(7) of the Regulations? ... The terms of the Draft Agreement will not cause the Partnership to contravene the condition described in paragraph 5000(7)(d) of the definition of "qualified limited partnership" that the interests of limited partners are described by reference to units of the partnership that are identical in all respects. ... The terms of the Draft Agreement will not cause the Partnership to contravene the conditions described in paragraphs 5000(7)(a), (b) and (c) of the definition of "qualified limited partnership". ...

Where fees are deductible in computing the income of a trust, the payment of those fees by the trust will not contravene subparagraph 73(1)(c)(i) of the Act. ... As indicated in paragraph 5(g) of Interpretation Bulletin IT-207R, fees paid to a trustee out of the capital of the trust for the administration of the trust will generally not contravene subparagraph 73(1)(c)(ii) of the Act. ...

Where fees are deductible in computing the income of a trust, the payment of those fees by the trust will not contravene subparagraph 73(1)(c)(i) of the Act. ... As indicated in paragraph 5(g) of Interpretation Bulletin IT-207R, fees paid to a trustee out of the capital of the trust for the administration of the trust will generally not contravene subparagraph 73(1)(c)(ii) of the Act. ...

It is our opinion that the payment of an interest bonus into an RRSP does not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act and therefore, no advantage will be considered to have been extended to the annuitant of the RRSP by such a payment. ...

We acknowledge receipt of copies of two letters issued by the Department of Insurance indicating that the issuance of shares for cash and goodwill does not contravene the provisions of the Canadian and British Insurance Companies Act. ...

It is our opinion that the payment of an interest bonus into an RRSP does not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act and therefore, no advantage will be considered to have been extended to the annuitant of the RRSP by such a payment. ...

Your concern is whether the payment out of the trust to a spouse of the original income minus the income taxes paid on such income would contravene the definition of a spouse trust within the meaning of the Act. ...

It is our opinion that the payment of an interest bonus into an RRSP does not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act and therefore, no advantage will be considered to have been extended to the annuitant of the RRSP by such a payment. ...

It would be necessary to examine the particular terms, with respect to the holding and the surrender of the interests identical to the particular interest in a particular non-resident entity, to determine if these terms are such that they contravene the obligation of the non-resident entity to accept the surrender at the demand of the holders or the obligation of the holders to accept the surrender at the demand of the non-resident entity. ... It is possible, however, that following the examination of the particular terms in a given situation, we would accept that a relatively short minimum holding period would not contravene this obligation. ... On the other hand, if the terms provide, for example, that the interests will be surrendered on demand but that the determination of the redemption price and the date of payment of the redemption price will occur a certain time after the demand, this clause may not contravene the obligation to surrender on demand. ...

The confidentiality provisions of the Act prevent me from discussing the specific cases referred to in your letter; however, I can assure you that Revenue Canada treats all taxpayers in accordance with the law and these specific cases did not contravene any provisions of the Act. ...