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Miscellaneous severed letter

5 May 1992 Income Tax Severed Letter - Registered retirement savings plans — promotional activities by bank

XXX Notwithstanding the XXX arguments, XXX and there was, therefore, a contravention of paragraph 146(2)(c.4). ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Loss of Status by Non-profit Organization

Our Comments In our view, where an organization that has non-profit status reacquires memberships or, as in the case of a stock exchange, seats at an amount greater than cost and the reacquisition is not financed out of capital gains of the organization it would be making income available to its members in contravention of paragraph 149(1)(l) of the Income Tax Act. ...
Miscellaneous severed letter

7 June 1991 Income Tax Severed Letter - Award of Damages

The cases involved allegations of a contravention of applicable Human Rights legislation. ...
Administrative Letter

5 May 1992 Administrative Letter 9212746 F - RRSP Promotion

In our telephone conversation of April 30, 1992 (Spice/Turrell), you confirmed that your concern relates to the indirect nature of the campaign and the fact that it was not aimed specifically at individuals interested in purchasing RRSP's. 24(1) Notwithstanding the 24(1) arguments, 24(1) and there was, therefore, a contravention of paragraph 146(2)(c.4).  ...
Miscellaneous severed letter

4 March 1988 Income Tax Severed Letter 7-2563 - Payment by former employer pursuant to order of B.C. Council of Human Rights

The Council ordered the payment of the following amounts: (a) XXXX as compensation for wages lost by the taxpayer as a result of the contravention; and (b) XXXX in respect of humiliation and embarrassment. ...
Technical Interpretation - External

11 July 1997 External T.I. 9709085 - INDIAN BANDS PERFORMING A FUNCTION OF GOVERNMENT

The remedies for contravention of by-laws passed under these two sections are similar. ... Remedies for contravention of section 83 by-laws are the levying of interest charges and the enforcement of payment of amounts owing. ...
Technical Interpretation - Internal

11 May 2000 Internal T.I. 1999-0007237 - INVESTMENT BY RRSP/RRIF IN UNITS OF SBILP

Title may not pass in law and may result in contravention of paragraph (i) of subsection 5102(1) of the Regulations. 3. ... However, the cash and promissory notes may constitute "deposits" to the limited partnership in contravention of the definition of a SBILP in paragraph 5102(1)(i) of the Regulations. ...
Technical Interpretation - External

17 October 1990 External T.I. 9006635 F - Non-profit Organization

Our Comments In our view, where an organization that has non-profit status reacquires memberships or, as in the case of a stock exchange seats at an amount greater than cost and the reacquisition is not financed out of capital gains of the organization it would be making income available to its members in contravention of paragraph 149(1)(1) of the Income Tax Act. ...
Technical Interpretation - External

27 August 1991 External T.I. 9118995 F - Meaning of Salary and Wages

If the monies  are found to be other income includable under section 56 of the Act, 19(1)      will not be in contravention of Regulation 6801 of the Act.  ...
Miscellaneous severed letter

7 August 1991 Income Tax Severed Letter - Meaning of Salary and Wages

If the monies are found to be other income includable under section 56 of the Act, XXX will not be in contravention of Regulation 6801 of the Act. ...

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