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Technical Interpretation - External
7 December 2004 External T.I. 2003-0019751E5 - US Alternative Minimum Tax AMT and FTC
" Thus, even prior to the Kappus decision we recognized that the USAMT is not a "voluntary tax", as the U.S. government enforces the USAMT provisions despite the fact that these provisions contravene the Convention. ...
Technical Interpretation - External
19 May 1999 External T.I. 9833905 - DSLP 6801(A) - NEW T4 REFERENCES
Clause XXXXXXXXXX contravenes Regulation 6801(a) which requires the Plan to be established for the main purpose of permitting the employee to fund, through salary or wage deferrals, a leave of absence from the employee’s employment. ...
Miscellaneous severed letter
30 April 1987 Income Tax Severed Letter
We are of the views that our interpretation of Reg. 1205 (b) does not contravene the rule expressed by Willie J. in Philips v. ...
Technical Interpretation - Internal
15 February 2023 Internal T.I. 2022-0925731I7 - Qualified donee - Article XXI of Canada-US Treaty
However, the charity may be subject to certain penalties or have its tax-exempt registered status revoked if it contravenes the rules in sections 149.1 or 149.2 of the Act. ...
Technical Interpretation - External
25 October 2023 External T.I. 2022-0927891E5 - XXXXXXXXXX Program - Deductibility of Costs
., accrual basis) appears to be consistent with well-accepted business principles, which includes GAAP, the SCC in Canderel was clear that to ascertain profit for tax purposes, the proposed income tax treatment cannot contravene any provisions of the Act or established case law principles. ...
Ruling
2005 Ruling 2004-0067531R3 - Distribution of funds by a public corporation
The reduction in stated capital is necessary to permit the payment of a dividend on the Class B Common Shares and Class C Common Shares (see Paragraph 29(v) below) which will not contravene the solvency test XXXXXXXXXX. ... The purpose of the Proposed Transactions set out in Paragraph 29(iv) and 29(vi) above is to ensure that the taxable dividend to be paid on the Class B Common Shares and the Class C Common Shares will not contravene the solvency test in subsection 38(3) of the OBCA. ...
Ruling
2020 Ruling 2019-0819971R3 - Loss Consolidation Ruling
The principal amount of the Daylight Loan will not exceed the amount that Lossco could reasonably be expected to borrow from an arm’s length financial institution and will not cause Lossco to contravene any debt covenants. ... The purpose of incorporating Newco is to have Newco issue the Newco Preferred Shares to NewLossco, rather than having Lossco issue preferred shares directly to NewLossco which would result in corporate incest and contravene corporate law constraints. 46. ...
Ruling
2022 Ruling 2021-0910431R3 - Loss consolidation arrangement
The principal amount of the Daylight Loan will not exceed the amount that Parent could borrow from an arm's length financial institution and will not cause Parent to contravene any debt covenants. ... The aggregate principal amount of the New LP Loan will not cause Parent or New LP to contravene any debt covenants in existence. ...
Conference
10 October 2008 Roundtable, 2008-0285071C6 F - Fiducie en faveur de soi
In such a case, the potential transferee would be entitled to receive or otherwise obtain the use of any income or capital of the trust following such a transfer, which would contravene one of the conditions provided in subparagraph 73(1.01)(c)(ii) of the ITA. c) The previous answers would not be different, whether the sale of his beneficiary rights in the trust takes place immediately or five years after the transfer of the property to the trust. ...
Ruling
30 November 1996 Ruling 9700303 - XXXXXXXXXX EXECUTIVE INCENTIVE ARRANGEMENT
(g)In the event of a stock dividend, stock split, combination or exchange of shares, merger, consolidation, spin-off or other distribution (other than normal cash dividends) of XXXXXXXXXX assets to shareholders, or any other change affecting the XXXXXXXXXX Shares, such proportionate adjustments, if any, as the Personnel Committee of the Board of Directors in its discretion may deem appropriate to reflect such change, will be made with respect to the number of Units outstanding under the XXXXXXXXXX, provided (as confirmed in the above-referenced telephone conversation of XXXXXXXXXX) such proportionate adjustment does not contravene the condition in 5(k) below. ...