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I can assure you that Revenue Canada treats all taxpayers in accordance with the law and the specific cases referred to in the Auditor General's report did not contravene any provisions of the Act. ...

Consequently not making deferrals during one or more of the years in the deferral period will not contravene regulation 6801. ...

In addition, contributions in-kind must not contravene the investment restrictions imposed by section 8514 of the Income Tax Regulations (the "Regulations"). ...

Principal Issues: Would cost-of-living adjustments for a fixed period of time contravene paragraph 8603(2)(a) of the Regulations? ...

Such an interpretation would contravene subparagraph 212(1)(b)(vii) which requires that “the corporation may not under any circumstances be obliged to pay more than 25%...except in the event of default. ...

It is our general view that where an asset/liability management activity is undertaken solely to protect the investments of the MIC, such activity would not necessarily contravene the requirements of paragraph 130.1(6)(b) of the Act. ...

The confidentiality of such information is protected by subsection 241(1) of the Income Tax Act and subsection 239(2.2) of the Income Tax Act provides that any person who contraveners subsection 241(1) is liable to a fine of $5000, imprisonment for 12 months, or both. ...

Should a master trust contravene one of the conditions in paragraphs (a) to (e) of Regulation 5001 it would, presumably, cease to be an exempt corporation under paragraph 149(1)(o.4) of the Act. ...

It is our general view that where an asset/liability management activity is undertaken solely to protect the investments of the MIC, such activity would not necessarily contravene the requirements of paragraph 130.1(6)(b) of the Act. ...

1993 Administrative Letter 9336656 F- Paragraph 5000(1) of the Income Tax Regulations Unedited CRA Tags ITR 5000(1) RULINGS DIRECTORATE CORRESPONDENCE SUMMARY PRINCIPAL ISSUES: Will a pooled fund contravene reg 5000(1)(e) if it inadvertantly holds excess foreign property for a short period of time. ...