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Technical Interpretation - Internal

15 November 1990 Internal T.I. 902957 F - Political Donations

Thus use of political donations in the manner described above would not only be inconsistent with the intent of the political contribution tax credit provisions of the Income Tax Act but could in some cases also contravene the NPO provisions of the Income Tax Act or certain provisions of the Canada Elections Act. ...
Miscellaneous severed letter

5 October 1988 Income Tax Severed Letter 7-2994 - [881005]

XXXX In our research, we failed to determine the existence of such a policy but did, in fact, note a number of Rulings Directorate opinion letters which would contravene such a rule. ...
Miscellaneous severed letter

15 November 1990 Income Tax Severed Letter

Thus use of political donations in the manner described above would not only be inconsistent with the intent of the political contribution tax credit provisions of the Income Tax Act but could in some cases also contravene the NPO provisions of the Income Tax Act or certain provisions of the Canada Elections Act. ...
Ruling

2014 Ruling 2013-0511991R3 - Loss consolidation

The principal amount of Loan 1 will not exceed the amount that ACo could reasonably be expected to borrow from an arm's-length financial institution and will not cause ACo to contravene any debt covenants. ... The principal amount of the Lossco 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 ACo, rather than having Lossco issue preferred shares directly to ACo which would result in corporate incest and contravene corporate law constraints. 46. ...
Ruling

2017 Ruling 2017-0688351R3 - Loss Consolidation

The principal amount of the LossCo Loan will not exceed the amount that LossCo could reasonably be expected to borrow from an arm’s length XXXXXXXXXX and will not cause LossCo to contravene any debt covenants. ... The principal amount of Loan 1 will not exceed the amount that LossCo and NewLossCo could reasonably be expected to borrow from an arm’s length XXXXXXXXXX and will not cause LossCo or NewLossCo to contravene any debt covenants in existence. ... 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. 44. ...
Ruling

2000 Ruling 9911433 - QLP XXXXXXXXXX

Provided that the Partnership qualifies as a "qualified limited partnership" within the meaning of subsection 5000(7) of the Regulations in all other respects, the receipt of incidental passive transaction fee income as described in 9 above by the Partnership will not, in and of itself, cause the Partnership to contravene paragraph 5000(7)(f) of the Regulations, and neither the payment of the Management Fee by the Partnership to the General Partner as described in 11 above nor the use of the Preferential Return and the payment of the Catch-Up Payment as described in 10(b) above will, together or independently, in and of themselves, cause the Partnership to contravene either paragraph 5000(7)(b) or (c) of the Regulations. ...
GST/HST Interpretation

7 February 1995 GST/HST Interpretation 11820-1 - Related Convention Supplies

It is my opinion that separately identifying room rental fees and catering fees would not contravene the Act. ... However, negotiations resulting in an unreasonable high fee for room rental offset by a unreasonably lower fee for catering appears to contravene subsection 153(2) of the Act. ...
Conference

7 October 2005 Roundtable, 2005-0141181C6 F - Fiducie au profit du conjoint

In the CRA's opinion, would such a clause contravene the condition set forth in paragraph 70(6)(b)(ii) of the ITA in such a way that the trust would not qualify as a trust for the exclusive benefit of the spouse? ...
Technical Interpretation - External

4 March 1997 External T.I. 9619975 - CORPORATIONS OF B.C. REAL ESTATE SALESPEOPLE

You indicate that the Superintendent of Real Estate has issued an administrative ruling stating that such an assignment is acceptable and does not contravene any provisions of the Real Estate Act. ...
Ruling

30 November 1995 Ruling 9625593 - LOSS CONSOLIDATION

The amount representing this reduction will be paid to its sole shareholder, XXXXXXXXXX As per subsection 84(4), this reduction is not a dividend. 21.The funds received upon the reduction of the PUC by XXXXXXXXXX, will be used by XXXXXXXXXX to reimburse the loan from the financial institution described in paragraph 18. 22.The proposed reduction of the PUC described in paragraph 20 does not contravene any provision of the Canada Business Corporations Act. 23.The reduction of PUC to a maximum amount of $XXXXXXXXXX does no exceed the PUC of $XXXXXXXXXX as calculated under subsection 89(1) of the Act. ...

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