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Results 81 - 90 of 694 for contravene

9 January 1997 External T.I. 9640105 - REIMBURSEMENT OF RRSP ADMIN FEES

XXXXXXXXXX 964010 Attention: XXXXXXXXXX January 9, 1997 Re: Registered Retirement Savings Plan ("RRSP") Trustee or Administration Fees This is in reply to your facsimile transmission of December 3, 1996, in which you ask whether the payment of the above-noted fee by the agent of the RRSP trustee would contravene paragraph 146(2)(c.4) of the Income Tax Act (the "Act"). ... Thus it is our view that where the terms of the RRSP plan document provide that the trustee or administration fee may be recovered from the plan funds, the payment of such a fee either with plan funds or by the agent of the RRSP trust does not contravene the condition in paragraph 146(2)(c.4) of the Act. ...

2 May 1996 External T.I. 9611675 - RRSP INVESTMENT IN NON-ARM'S LENGTH MORTGAGE

Reasons: Contravenes 146(2)(c.4) inasmuch as it is an advantage to the non-arm's length mortgagor; may contravene 4900(1)(j) if collection by annuitant results in mortgage not being "administered" by an approved lender. 961167 XXXXXXXXXX P. ...

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 ...

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. ...

20 August 2018 External T.I. 2018-0739761E5 - TFSA contributions

20 August 2018 External T.I. 2018-0739761E5- TFSA contributions Unedited CRA Tags 146.2(2)(c), 207.01(1) "advantage", 74.1(2) Principal Issues: Whether payments made by a third party on behalf of an individual directly to their TFSA in several scenarios contravene the condition in paragraph 146.2(2)(c) that prohibits anyone other than the holder from making contributions to the TFSA. ... Doiron August 20, 2018 Dear XXXXXXXXXX: Re: Contributions to a tax-free savings account This is in reply to your email of January 15, 2018 in which you ask for confirmation that payments made to a tax-free savings account (“TFSA”) in each of the following three scenarios do not contravene the condition in paragraph 146.2(2)(c) (footnote 1) that prohibits anyone other than the holder from making contributions to the TFSA. ...

Netupsky v. R., [1996] 2 CTC 29, 96 DTC 6129

.* [2] As for the contention that the Alternative Minimum Tax provisions are invalid because they contravene the Charter, specifically section 15 thereof, it appears to us, as it appeared to the Tax Court judge, simply untenable. ...

2000 Ruling 2000-0006283 - QLP SUPPLEMENTAL

Principal Issues: 1) Amendment to proposed transactions describing residence of general partner, types of limited partners, fuller description of management fees, and to amend rulings to confirm description in partnership agreement of limited partners' interests comply with Regulations and agreement as a whole does not contravene specific provisions in Regulation. 2) Can we rule that the terms of a partnership, as set out in a draft agreement, comply with the definition of "qualified limited partnership" in subsection 5000(7) of the Regulations? ... The terms of the Draft Agreement will not cause the Partnership to contravene the condition described in paragraph 5000(7)(d) of the definition of "qualified limited partnership" that the interests of limited partners are described by reference to units of the partnership that are identical in all respects. ... The terms of the Draft Agreement will not cause the Partnership to contravene the conditions described in paragraphs 5000(7)(a), (b) and (c) of the definition of "qualified limited partnership". ...

Lewis v. M.N.R., 84 DTC 6550, [1984] CTC 642 (FCTD)

While I would agree with these views I am bound by the majority judgment in which the point is made by Justice Pratte at pages 12-13: It is common ground that subsection 231(4) does not contravene the charter insofar as it gives the Minister, when he has valid grounds for believing that an offence has been committed by a taxpayer, the power to authorize a search and seizure in respect of that offence. ... In my view, that subsection violates section 8 of the Constitution Act, 1982 in that it contravenes the right of the taxpayer “‘to be secure against unreasonable search or seizure.” ... Having concluded that the authorizations for search granted pursuant to subsection 231(4) fo the Income Tax Act must be quashed as it contravenes section 8 of the Constitution Act, 1982, and is therefore inoperative and is of no force or effect the only question remaining to be considered is whether this would necessarily result in return of the documents seized. ...

14 November 1990 External T.I. 9026015 F - Spousal Trust Income

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. ...

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