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Rulings Given Provided that the above-mentioned facts and proposed transactions are accurate and constitute complete disclosure of all the relevant facts and proposed transactions, that the Assignment and Assumption Agreements are substantially the same as the documents provided to us, that the proposed transactions are carried out as described herein, and that the Assignment and Assumption Agreements for the assignment and assumption of A Co's rights and obligations under the Contracts are executed and assented to by each of the Claimants, A Co and B Co, we rule as follows: Because the Assignment and Assumption Agreements will not be considered to contravene the requirements contained in paragraph 5 of IT-365R2 for structured settlements that an annuity be non-assignable, non-commutable and non-transferable (see comment below), the Assignment and Assumption Agreements, in and by themselves, will not cause the payments received by the Claimants (or their respective estates or such other secondary payees related to the Claimants as may be named in the Contracts) under the structured settlements, as described in 6, to be subject to taxation in their hands under any provision of the Act. Comment: Provided that the Claimants have consented to the assignment of the structured settlements as described in the Ruling, in our view, the Assignment and Assumption Agreements, in and by themselves, will not contravene the restriction contained in paragraph 5 of IT-365R2 that an annuity be non-assignable, non-commutable and non-transferable. ...

(d) exempt from personal liability for its debts, obligations or acts those individual members of the corporation who do not contravene the provisions of the enactment establishing the corporation;... ... (d) exempt from personal liability for its debts, obligations or acts those individual members of a corporation that is not an unlimited liability corporation as defined in the Business Corporations Act who do not contravene the provisions of the enactment establishing the corporation;... ...

The confidentiality provisions of the Income Tax Act prevent me from discussing the cases referred to in the Auditor General's report; however, I can assure you that Revenue Canada treats all taxpayers in accordance with the law and that these cases did not contravene any provisions of the Act. ...

The confidentiality provisions of the Income Tax Act prevent me from discussing the specific cases referred to in the Auditor General's report; however, I can assure you that these specific cases did not contravene any provisions of the Act. ...

I can assure you that Revenue Canada treats all taxpayers in accordance with the law and the specific cases referred to in the Auditor General's report did not contravene any provisions of the Act. ...

Consequently not making deferrals during one or more of the years in the deferral period will not contravene regulation 6801. ...

In addition, contributions in-kind must not contravene the investment restrictions imposed by section 8514 of the Income Tax Regulations (the "Regulations"). ...

Principal Issues: Would cost-of-living adjustments for a fixed period of time contravene paragraph 8603(2)(a) of the Regulations? ...

Such an interpretation would contravene subparagraph 212(1)(b)(vii) which requires that “the corporation may not under any circumstances be obliged to pay more than 25%...except in the event of default. ...

It is our general view that where an asset/liability management activity is undertaken solely to protect the investments of the MIC, such activity would not necessarily contravene the requirements of paragraph 130.1(6)(b) of the Act. ...