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Technical Interpretation - External

8 July 2003 External T.I. 2003-0016045 - DEFERRED SALARY LEAVE PLAN

Position: No Reasons: It contravenes the provisions of 6801(a)(iii) of the Regulations XXXXXXXXXX 2003-001604 M. ...
Technical Interpretation - External

8 July 2003 External T.I. 2003-0021255 - DEFERRED SALARY LEAVE PLAN

Position: No Reasons: It contravenes the provisions of 6801(a)(iii) of the Regulations XXXXXXXXXX 2003-002125 M. ...
Ruling

2 March 2001 Ruling 2001-0070233 - Collective Agreement, PBSA

You have requested an income tax ruling that the existing terms of a collective agreement, as they relate to a registered pension plan subjected to the Pension Benefits Standards Act, 1985 ("PBSA"), would not contravene the PBSA. ...
Technical Interpretation - External

16 August 2001 External T.I. 2001-0089635 - INCENTIVES FOR OPENING RRSP

As noted by you, in that letter we indicated, that an offer would contravene the provisions of paragraph 146(2)(c.4) of the Act if it is linked in any manner to the issue or the existence of an RRSP. ...
Technical Interpretation - External

21 February 2002 External T.I. 2001-0100075 - ADVANTAGES UNDER 146(13.1)

In our view, an offer would contravene the provisions of paragraph 146(2)(c.4) of the Act if it is linked in any manner to the issue or the existence of an RRSP. ...
Technical Interpretation - External

6 December 2002 External T.I. 2002-0171745 - BANKED OVERTIME

You inquire whether or not the article contravenes the Income Tax Act (the "Act"). ...
Technical Interpretation - External

10 January 2001 External T.I. 2000-0007835 - EXEMP FROM WITHHOLDING TAX ON INTEREST

Storry Attention: January 10, 2001 Dear Sirs: Re: Withholding Exemption on Interest Paid to Non-Resident Lender This is in response to your letter dated February 11, 2000, wherein you requested our views regarding the withholding tax exemption pursuant to subparagraph 212(1)(b)(vii) of the Income Tax Act (the "Act") and whether the occurrence of specific events would contravene this exemption. ...
Ministerial Letter

31 August 1990 Ministerial Letter 900508 F - Shareholder Benefit of "Sole Purpose Corporations" Holding U.S. Residential Real Estate

In addition we note that depending upon the particular facts the issue of the preferred shares may contravene the condition (number 3) that the only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder.  ...
Miscellaneous severed letter

31 August 1990 Income Tax Severed Letter ACC9243 - Shareholder Benefit of "Sole Purpose Corporations" Holding U.S. Residential Real Estate

In addition we note that depending upon the particular facts the issue of the preferred shares may contravene the condition (number 3) that the only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. ...
Miscellaneous severed letter

2 October 1992 Income Tax Severed Letter 9222163 - Activities of a Mortgage Investment Corporation

While again a question of fact, it is our general view that where this is undertaken solely to protect the investments of the mortgage investment corporation, such action would not contravene the provisions of paragraph 130.1(6)(b) of the Act. ...

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