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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. ...
Old website (cra-arc.gc.ca)

How to submit information to the Offshore Tax Informant Program

Sufficient, specific and credible facts relating to the alleged international tax non-compliance, such as: the source and amount of undeclared income; details of offshore assets (for example: country(ies) where accounts or assets are held, name of financial institution, account numbers, foreign real estate address); details of trusts held offshore (for example: name of beneficiaries, type of trust, location held); the tax years involved; where applicable, a description of how the transactions contravene Canadian tax law; and a description of how you learned of or obtained this information. ...
Scraped CRA Website

Federal Excise Stamp Mandatory on Tobacco Products as of July 1, 2012

Any person who contravenes this requirement is liable to a fine, imprisonment, or both. ...
Current CRA website

How to submit information to the Offshore Tax Informant Program

Sufficient, specific and credible facts relating to the alleged international tax non-compliance, such as: the source and amount of undeclared income; details of offshore assets (for example: country(ies) where accounts or assets are held, name of financial institution, account numbers, foreign real estate address); details of trusts held offshore (for example: name of beneficiaries, type of trust, location held); the tax years involved; where applicable, a description of how the transactions contravene Canadian tax law; and a description of how you learned of or obtained this information. ...
Excise Interpretation

29 September 2017 Excise Interpretation 185869 - [Excise Stamp - Tobacco Products]

Therefore, affixing a stamp or removing [a] [Jurisdiction B] stamp and applying [a] [Jurisdiction A] stamp ([or] vice versa) on a [package of tobacco product] that was previously imported would contravene the Act and its Regulations and be subject to the applicable penalties. ...
Current CRA website

Export Documentation

If a person contravenes or fails to comply with the requirements of the Act, they may be subject to a penalty or face charges under the Act. ...
Current CRA website

Compliance Bulletin No. 3

This practice may contravene paragraph 147.4(1)(a), which states that when a member elects to purchase an annuity, the annuity purchased must not be materially different than the benefits that would have been provided to the individual under the RPP. ...

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