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Miscellaneous severed letter

7 November 1990 Income Tax Severed Letter 158

This "bonus" interest would be paid into an RRSP rather than to the annuitant and you ask if this would contravene paragraph 146(2)(c.4) of the Act. It is our view that payment of bonus interest into an RRSP does not contravene paragraph 146(2)(c.4) of the Act. ...
Miscellaneous severed letter

20 November 1990 Income Tax Severed Letter

This "bonus" interest would be paid into an RRSP rather than to the annuitant and you ask if this would contravene paragraph 146(2)(c.4) of the Act. It is our view that payment of bonus interest into an RRSP does not contravene paragraph 146(2)(c.4) of the Act. ...
Miscellaneous severed letter

28 June 1988 Income Tax Severed Letter 7-2949 - [Proposed amendment to a RRIF]

Noack 957-8963 Attention: Cecilia Lam---------------------- SUBJECT:XXXX We reply to your memorandum of June 6 concerning a proposed amendment to a RRIF issued by XXXX You ask whether subsection 4(1) of the amended plan would contravene the requirement in paragraph 146.3(2)(g) that no benefit that is conditional on the existence of the plan may be extended to the annuitant. ... Therefore, the provision for payment of a guaranteed amount as intended by subsection 4(1) of the amended plan does not contravene the condition for acceptance for registration in paragraph 146.3(2)(g). for Director Financial Industries Division Rulings Directorate ...
Miscellaneous severed letter

7 October 1987 Income Tax Severed Letter 5-3801 - [Deferred Compensation/Leave of Absence Plan]

Paragraph 3(a) on page 1 of the document titled "Facts and Proposed Transactions" when read in conjunction with paragraph two of the Memorandum of Agreement (the "Agreement") may contravene clause 6801(a)(i) of the Regulations as the total deferral period may exceed six years which is the maximum allowed under the Regulations. 2. Clause 3(f)(ii) of the Agreement contravenes clause 6801(a)(i) of the Regulations as the leave period must not be of less than six months and the deferral period, as mentioned before, must not exceed six years. 3. ...
Miscellaneous severed letter

14 November 1990 Income Tax Severed Letter

Where fees are deductible in computing the income of a trust, the payment of those fees by the trust will not contravene subparagraph 73(1)(c)(i) of the Act. ... As indicated in paragraph 5(g) of Interpretation Bulletin IT-207R, fees paid to a trustee out of the capital of the trust for the administration of the trust will generally not contravene subparagraph 73(1)(c)(ii) of the Act. ...
Miscellaneous severed letter

11 February 1985 Income Tax Severed Letter RCT 5-7269 F

We acknowledge receipt of copies of two letters issued by the Department of Insurance indicating that the issuance of shares for cash and goodwill does not contravene the provisions of the Canadian and British Insurance Companies Act. ...
Miscellaneous severed letter

7 April 1991 Income Tax Severed Letter - Tax implications of a payment of an interest bonus into a registered retirement savings plan

It is our opinion that the payment of an interest bonus into an RRSP does not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act and therefore, no advantage will be considered to have been extended to the annuitant of the RRSP by such a payment. ...
Miscellaneous severed letter

29 September 1978 Income Tax Severed Letter

Your concern is whether the payment out of the trust to a spouse of the original income minus the income taxes paid on such income would contravene the definition of a spouse trust within the meaning of the Act. ...
Miscellaneous severed letter

4 April 1991 Income Tax Severed Letter

It is our opinion that the payment of an interest bonus into an RRSP does not contravene the provisions of paragraph 146(2)(c.4) of the Income Tax Act and therefore, no advantage will be considered to have been extended to the annuitant of the RRSP by such a payment. ...
Miscellaneous severed letter

4 November 1999 Income Tax Severed Letter 9928786 - TRUSTEE FEES PAID FROM RRSP

An amendment to existing RRSP plans to allow for such reimbursements would not, in our view, contravene the registration requirements contained in subsection 146(2) of the Act. ...

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