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Miscellaneous severed letter
7 August 1990 Income Tax Severed Letter - Administrative position concerning application of subsection 15(1) of the Income Tax Act as it relates to “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
10 January 1992 Income Tax Severed Letter 9133145 - Deferred Salary Leave Plan
Paquette at (613) 954-2522 or to the following address: Coverage Policy and Legislation Section Source Deductions Division Revenue Canada Taxation 875 Heron Road Ottawa, Ontario K1A 0L8 If the Plan is adjusted to correct the aforementioned problems it is our opinion that it will not contravene the provisions in Regulation 8801. ...
Old website (cra-arc.gc.ca)
Tax Avoidance
Tax avoidance occurs when a person undertakes transactions that contravene specific anti-avoidance provisions. ... Tax avoidance results when actions are taken to minimize tax, while within the letter of the law, those actions contravene the object and spirit of the law. ...
Current CRA website
Tax Avoidance
Tax avoidance occurs when a person undertakes transactions that contravene specific anti-avoidance provisions. ... Tax avoidance results when actions are taken to minimize tax, while within the letter of the law, those actions contravene the object and spirit of the law. ...
Current CRA website
Tax Avoidance
Tax avoidance occurs when a person undertakes transactions that contravene specific anti-avoidance provisions. ... Tax avoidance results when actions are taken to minimize tax, while within the letter of the law, those actions contravene the object and spirit of the law. ...
Technical Interpretation - Internal
14 August 2015 Internal T.I. 2013-0504471I7 - RDSPs and bankruptcy
You ask whether this would contravene the registration conditions in paragraphs 146.4(4)(a) and (i) of the Income Tax Act (the “Act”). ...
Technical Interpretation - Internal
10 May 2016 Internal T.I. 2016-0644761I7 - RPP borrowing
10 May 2016 Internal T.I. 2016-0644761I7- RPP borrowing Unedited CRA Tags 8502(i) Principal Issues: Whether a registered pension plan contravenes the borrowing restriction in Regulation 8502(i). ...
Conference
29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6 - GAAR & 21-year rule planning
This contravenes one of the underlying principles in the taxation of capital gains regime, which is to prevent the indefinite deferral of tax on capital gains. ...
Conference
13 June 2017 STEP Roundtable Q. 2, 2017-0693321C6 - GAAR and 21-year planning
This contravenes one of the underlying principles in the taxation of capital gains regime, which is to prevent the indefinite deferral of tax on capital gains. ...
Conference
6 October 2006 Roundtable, 2006-0196221C6 F - Calcul du revenu d'entreprise d'un non-résident
" Since the method proposed in document #9235160 takes into account the fair market value of the manufactured or processed goods, we are of the opinion that this method would not result in a portion of the non-resident's profit that is attributable to the manufacturing of the goods being taxed in Canada, nor would it contravene paragraph 4(1)(b) ITA. ...